Re: [PSES] UK The Product Safety and Metrology etc. (Amendment) Regulations 2024

[Scott Xe]

Dear Charlie,

Appreciate your updates!!  What is the distance to become an official
legislation?

Currently, can we use the EU CE compliance DoC texts in UKCA DoC and bear
the UKCA mark on the product without re-test according to Designed
Standards and Approval Body cert?

Thanks and regards,

Scott


On Fri, 19 Apr 2024 at 16:09, Charlie Blackham 
wrote:

> UK has published draft legislation to allow continued acceptance of CE
> Marking past the end of 2024 in the "The Product Safety and Metrology etc.
> (Amendment) Regulations 2024" along with an explanatory memorandum.
> The law is due to come into force on 1st October ahead of the current 31
> December deadline.
>
>
>
> The Product Safety and Metrology etc. (Amendment) Regulations 2024
> (legislation.gov.uk)
> 
>
>
>
> Best regards
>
> Charlie
>
>
>
> *Charlie Blackham*
>
> *Sulis Consultants Ltd*
>
> *Mead House*
>
> *Longwater Road*
>
> *Eversley*
>
> *RG27 0NW*
>
> *UK*
>
> *Tel: +44 (0)7946 624317*
>
> *Email: **char...@sulisconsultants.com *
>
> *Web: https://sulisconsultants.com/  *
>
> Registered in England and Wales, number 05466247
>
>
> --
>
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Re: [PSES] Class 1 appliance

[Scott Xe]

Dear John,

Thanks for your comments.  I have some below results of further
investigation to share with you.

On Mon, 6 Nov 2023 at 22:22, John Woodgate  wrote:

> I put some comments below.
> On 2023-11-06 14:08, Scott Xe wrote:
>
> Last week, we received a sample of an induction hob from a supplier. The
> unit is fitted with a 3-core power card and does not have a class II
> symbol. The earthing core is terminated at a small copper pad on the
> printed circuit board with a protective ground symbol (IEC 60417 - 5019)
> next to the terminal.  It is shocking to note that the copper pad is
> standalone and not connected to the unit circuitry.  We made an inquiry to
> the supplier and replied that the product was designed by the engineer who
> left the company.
>
> *JMW: That alone should indicate that you should have nothing to do with
> the product, unless you are a test house, paid for assessing its safety.*
>

SX: According to the circuit diagram, the PCB missed out a resistor
connecting between 2 capacitors and the isolated earth pad.  The earthing
path is for EMC compliance and the earthing is considered as a functional
earth.  The 2 capacitors must be Y1 class to fulfil safety requirements.

>
> I have two questions regarding the appliance. Firstly, can it be rated as
> a class 1 appliance?
>
> *JMW: If it passes all the safety tests for a Class 1 appliance, it is a
> Class 1 appliance. But it remains a suspect design.*
>

SX: Obviously the appliance does not rely on extra earth protection against
electrical shock.  The live parts must have double or reinforced
insulation in order to meet class II requirements.

>
> Secondly, what are the main purposes of installing a 3-core power cable
> that has no obvious functionality?
>
> *JMW: There is a strong temptation to do that if it's too difficult to
> meet the Class II requirements.*
>

SX: The earth core is used for grounding the interference.

>
>
> Additionally, while examining the PCB layout, I noticed punched holes for
> a resistor and two capacitors connected in series, with the capacitors
> connected in parallel first. Currently, there are no components present in
> those holes. I would like to know if these components are necessary for EMC
> compliance.
>
> *JMW: There is no way anyone can advise you on that, even if we could see
> where the 'missing' components appear in the schematic. You have to test it
> as it is and see whether it meets the EMC requirements.*
>

SX: It is a common practice for oem manufacturers to design a product
embedded with the requirements of many customers.  The actual no of
components is subject to individual customer requirements.  It is likely to
cause confusion and/or miscommunication to the sample preparation team.

>
>
> Your advice is appreciated!
>
>
> Thanks and regards,
>
>
> Scott
>
>
>
>
> --
>
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[PSES] Class 1 appliance

[Scott Xe]

Last week, we received a sample of an induction hob from a supplier. The
unit is fitted with a 3-core power card and does not have a class II
symbol. The earthing core is terminated at a small copper pad on the
printed circuit board with a protective ground symbol (IEC 60417 - 5019)
next to the terminal.  It is shocking to note that the copper pad is
standalone and not connected to the unit circuitry.  We made an inquiry to
the supplier and replied that the product was designed by the engineer who
left the company.

I have two questions regarding the appliance. Firstly, can it be rated as a
class 1 appliance? Secondly, what are the main purposes of installing a
3-core power cable that has no obvious functionality?


Additionally, while examining the PCB layout, I noticed punched holes for a
resistor and two capacitors connected in series, with the capacitors
connected in parallel first. Currently, there are no components present in
those holes. I would like to know if these components are necessary for EMC
compliance.


Your advice is appreciated!


Thanks and regards,


Scott

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Re: [PSES] AW: [PSES] SV: [PSES] User manual by accompanying documents or via affixed QR

[Scott Xe]

Dear Bernd & Charlie,

Thanks for your advice!!  For the time being, we have to put the safety
instructions with the unit.

Best regards,

Scott


On Tue, 15 Aug 2023 at 15:54, Dürrer Bernd  wrote:

> Dear Scott,
>
>
>
> I agree with Charlie Blackham’s conclusions on instructions in electronic
> format embedded in the device. I am not aware of any plans to amend LVD and
> RED to align their requirements on instructions with the new Machinery
> regulation. However, as the monetary and environmental costs due to
> extensive paper-based documentation has been identified as one of the
> problems of the old Machinery Directive (cf.
> eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52021SC0082=3,
> p. 21 and 41ff.), I hope that there will be an initiative to introduce an
> option for digital documentation also in other directives and regulations.
>
>
>
> Currently, you have to follow Charlie’s advice to provide a short printed
> guide with the mandatory instructions and safety information. If you are
> lucky and all mandatory information for your product can be presented
> graphically, you may avoid to translate the document to the 24 official EU
> languages and the additional 3 languages of states in the European Economic
> Area (EEA) and the EU-Turkey Customs Union (DocsRoom - European
> Commission (europa.eu) <https://ec.europa.eu/docsroom/documents/38022>,
> p. 246).
>
>
>
> Kind regards,
>
>
>
> Bernd
>
>
>
>
>
>
>
> *Von:* Scott Xe 
> *Gesendet:* Dienstag, 15. August 2023 08:24
> *An:* Dürrer Bernd 
> *Cc:* EMC-PSTC@listserv.ieee.org
> *Betreff:* Re: [PSES] AW: [PSES] SV: [PSES] User manual by accompanying
> documents or via affixed QR
>
>
>
> [EXTERNAL E-MAIL] This email originated from outside of the organization.
> Do not click links or open attachments unless you recognize the sender.
>
> Dear Bernd,
>
>
>
> Although LVD and RED are modern directives, they are considered old
> compared with MR issued in 2023.  Could the view on instructions in
> electronic format be aligned all together one day?
>
>
>
> Thanks and regards,
>
>
>
> Scott
>
>
>
>
>
> On Tue, 15 Aug 2023 at 13:27, Scott Xe  wrote:
>
> Dear Bernd,
>
>
>
> Thanks for your good references!  The LVD and RED do not decline the
> instructions in electronic format.  What about those instructions embedded
> in the ROM as the memory is not expensive as before?  For example, mobile
> phones, TVs, etc.
>
>
>
> Regards,
>
>
>
> Scott
>
>
>
>
>
>
>
> On Mon, 14 Aug 2023 at 15:14, Dürrer Bernd  wrote:
>
> Hi Amund,
>
>
>
> In the European Union, it depends on the Directive that is applicable for
> your product. Both the Low Voltage Directive 2014/35/EU 
> (L_2014096EN.01035701.xml
> (europa.eu)
> <https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32014L0035#d1e32-371-1>,
> Article 6, Point 7, Article 8, Point 4, and Article 9, Point 2) and the
> Radio Directive 2014/53/EU (Consolidated TEXT: 32014L0053 — EN —
> 27.12.2022 (europa.eu)
> <https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:02014L0053-20221227#tocId84>,
> Article 10, Point 8, Article 12, Point 4, and Article 13, Point 2) require
> that manufacturers, importers, and distributors ensure that the product is
> accompanied by instructions and safety information. Only new regulation
> (EU) 2023/1230 that will replace Machinery Directive in January 2027 allows
> to provide instructions in digital format (L_2023165EN.01000101.xml
> (europa.eu)
> <https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32023R1230=1688119698228#d1e1695-1-1>,
> Article 10, Point 7).
>
>
>
> Kind regards,
>
>
>
> Bernd
>
>
>
> *Von:* John Woodgate 
> *Gesendet:* Sonntag, 13. August 2023 19:14
> *An:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Betreff:* Re: [PSES] SV: [PSES] User manual by accompanying documents or
> via affixed QR
>
>
>
> [EXTERNAL E-MAIL] This email originated from outside of the organization.
> Do not click links or open attachments unless you recognize the sender.
>
> No. I don't see so many EU documents as others here do, and it is very
> difficult, as you know, to find a document when you don't know a document
> title to look for. I am remembering information posted here quite a long
> time ago.
>
> On 2023-08-13 17:56, Amund Westin wrote:
>
> Yes, I was thinking that a short paper guide would help. URL link is
> important as you say, and QR are actually for advanced mobile users.
>
>
>
> Have you seen this issue been discussed in “Blue Guide” or other EU
> documents?
>
>
>

Re: [PSES] AW: [PSES] SV: [PSES] User manual by accompanying documents or via affixed QR

[Scott Xe]

Dear Bernd,

Although LVD and RED are modern directives, they are considered old
compared with MR issued in 2023.  Could the view on instructions in
electronic format be aligned all together one day?

Thanks and regards,

Scott


On Tue, 15 Aug 2023 at 13:27, Scott Xe  wrote:

> Dear Bernd,
>
> Thanks for your good references!  The LVD and RED do not decline the
> instructions in electronic format.  What about those instructions embedded
> in the ROM as the memory is not expensive as before?  For example, mobile
> phones, TVs, etc.
>
> Regards,
>
> Scott
>
>
>
> On Mon, 14 Aug 2023 at 15:14, Dürrer Bernd  wrote:
>
>> Hi Amund,
>>
>>
>>
>> In the European Union, it depends on the Directive that is applicable for
>> your product. Both the Low Voltage Directive 2014/35/EU 
>> (L_2014096EN.01035701.xml
>> (europa.eu)
>> <https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32014L0035#d1e32-371-1>,
>> Article 6, Point 7, Article 8, Point 4, and Article 9, Point 2) and the
>> Radio Directive 2014/53/EU (Consolidated TEXT: 32014L0053 — EN —
>> 27.12.2022 (europa.eu)
>> <https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:02014L0053-20221227#tocId84>,
>> Article 10, Point 8, Article 12, Point 4, and Article 13, Point 2) require
>> that manufacturers, importers, and distributors ensure that the product is
>> accompanied by instructions and safety information. Only new regulation
>> (EU) 2023/1230 that will replace Machinery Directive in January 2027 allows
>> to provide instructions in digital format (L_2023165EN.01000101.xml
>> (europa.eu)
>> <https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32023R1230=1688119698228#d1e1695-1-1>,
>> Article 10, Point 7).
>>
>>
>>
>> Kind regards,
>>
>>
>>
>> Bernd
>>
>>
>>
>> *Von:* John Woodgate 
>> *Gesendet:* Sonntag, 13. August 2023 19:14
>> *An:* EMC-PSTC@LISTSERV.IEEE.ORG
>> *Betreff:* Re: [PSES] SV: [PSES] User manual by accompanying documents
>> or via affixed QR
>>
>>
>>
>> [EXTERNAL E-MAIL] This email originated from outside of the organization.
>> Do not click links or open attachments unless you recognize the sender.
>>
>> No. I don't see so many EU documents as others here do, and it is very
>> difficult, as you know, to find a document when you don't know a document
>> title to look for. I am remembering information posted here quite a long
>> time ago.
>>
>> On 2023-08-13 17:56, Amund Westin wrote:
>>
>> Yes, I was thinking that a short paper guide would help. URL link is
>> important as you say, and QR are actually for advanced mobile users.
>>
>>
>>
>> Have you seen this issue been discussed in “Blue Guide” or other EU
>> documents?
>>
>>
>>
>>
>>
>>
>>
>>
>>
>> *Fra:* John Woodgate
>> *Sendt:* 13. august 2023 18:43
>> *Til:* EMC-PSTC@LISTSERV.IEEE.ORG
>> *Emne:* Re: [PSES] User manual by accompanying documents or via affixed
>> QR
>>
>>
>>
>> I believe that in Europe, it is not allowed. Current practice seems to be
>> to include with the product a short  'User Guide' or similar, which
>> includes the safety information required by the relevant safety standard,
>> and the DOC(s), together with a text link of the URL of the full User
>> Manual. You could include a QR code in addition, but not instead of the
>> text link, because about 15 % of people don't have a smart phone or don't
>> know much about using it for anything but calls, text messages and the
>> camera.
>>
>> On 2023-08-13 16:57, Amund Westin wrote:
>>
>> To avoid a lot of paper use, it is possible to leave a short instruction
>> with the product to enter a web site or use affixed QR code (on product) to
>> get access to the User manual and other relevant documentation?
>>
>> Should such a symbol Link https://www.iso.org/obp/ui#iso:grs:7000:3500
>>  also be attached when using QR code?
>>
>>
>>
>> Best regards
>>
>> Amund
>>
>>
>> --
>>
>> This message is from the IEEE Product Safety Engineering Society emc-pstc
>> discussion list. To post a message to the list, send your e-mail to All
>> emc-pstc postings are archived and searchable on the web at:
>> https://www.mail-archive.com/emc-pstc@listserv.ieee.org/
>> <https://www.mail-archive.com/emc-pstc@listserv.ieee.org/%20>
>>
>> Website: https://ewh.ieee.org/soc/pses/
>> Instruct

Re: [PSES] AW: [PSES] SV: [PSES] User manual by accompanying documents or via affixed QR

[Scott Xe]

Dear Bernd,

Thanks for your good references!  The LVD and RED do not decline the
instructions in electronic format.  What about those instructions embedded
in the ROM as the memory is not expensive as before?  For example, mobile
phones, TVs, etc.

Regards,

Scott



On Mon, 14 Aug 2023 at 15:14, Dürrer Bernd  wrote:

> Hi Amund,
>
>
>
> In the European Union, it depends on the Directive that is applicable for
> your product. Both the Low Voltage Directive 2014/35/EU 
> (L_2014096EN.01035701.xml
> (europa.eu)
> ,
> Article 6, Point 7, Article 8, Point 4, and Article 9, Point 2) and the
> Radio Directive 2014/53/EU (Consolidated TEXT: 32014L0053 — EN —
> 27.12.2022 (europa.eu)
> ,
> Article 10, Point 8, Article 12, Point 4, and Article 13, Point 2) require
> that manufacturers, importers, and distributors ensure that the product is
> accompanied by instructions and safety information. Only new regulation
> (EU) 2023/1230 that will replace Machinery Directive in January 2027 allows
> to provide instructions in digital format (L_2023165EN.01000101.xml
> (europa.eu)
> ,
> Article 10, Point 7).
>
>
>
> Kind regards,
>
>
>
> Bernd
>
>
>
> *Von:* John Woodgate 
> *Gesendet:* Sonntag, 13. August 2023 19:14
> *An:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Betreff:* Re: [PSES] SV: [PSES] User manual by accompanying documents or
> via affixed QR
>
>
>
> [EXTERNAL E-MAIL] This email originated from outside of the organization.
> Do not click links or open attachments unless you recognize the sender.
>
> No. I don't see so many EU documents as others here do, and it is very
> difficult, as you know, to find a document when you don't know a document
> title to look for. I am remembering information posted here quite a long
> time ago.
>
> On 2023-08-13 17:56, Amund Westin wrote:
>
> Yes, I was thinking that a short paper guide would help. URL link is
> important as you say, and QR are actually for advanced mobile users.
>
>
>
> Have you seen this issue been discussed in “Blue Guide” or other EU
> documents?
>
>
>
>
>
>
>
>
>
> *Fra:* John Woodgate
> *Sendt:* 13. august 2023 18:43
> *Til:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Emne:* Re: [PSES] User manual by accompanying documents or via affixed QR
>
>
>
> I believe that in Europe, it is not allowed. Current practice seems to be
> to include with the product a short  'User Guide' or similar, which
> includes the safety information required by the relevant safety standard,
> and the DOC(s), together with a text link of the URL of the full User
> Manual. You could include a QR code in addition, but not instead of the
> text link, because about 15 % of people don't have a smart phone or don't
> know much about using it for anything but calls, text messages and the
> camera.
>
> On 2023-08-13 16:57, Amund Westin wrote:
>
> To avoid a lot of paper use, it is possible to leave a short instruction
> with the product to enter a web site or use affixed QR code (on product) to
> get access to the User manual and other relevant documentation?
>
> Should such a symbol Link https://www.iso.org/obp/ui#iso:grs:7000:3500
>  also be attached when using QR code?
>
>
>
> Best regards
>
> Amund
>
>
> --
>
> This message is from the IEEE Product Safety Engineering Society emc-pstc
> discussion list. To post a message to the list, send your e-mail to All
> emc-pstc postings are archived and searchable on the web at:
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>
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>
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> unsubscribe) 
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Re: [PSES] BBC news article re Li-ion batteries...

[Scott Xe]

Dear Ted,

I couldn't agree with your views more.  It is crucial for us to tackle
these issues, despite the existing regulations and testing standards in
place.  The regulatory authorities and enforcement bodies must thoroughly
assess why these measures have proven ineffective in preventing the sale of
unsafe products in the market.

Regards,

Scott


On Fri, 28 Jul 2023 at 20:39, Ted Eckert <
07cf6ebeab9d-dmarc-requ...@listserv.ieee.org> wrote:

> I can give additional background on the reason why these fires have become
> common in New York. A large number of residents of New York City use
> delivery services for goods and food, such as Uber-Eats, DoorDash, and
> GrubHub. The adoption of these delivery services accelerated during the
> COVID lockdown, and it has become a major business in the city. The drivers
> for these services are contractors, not employees, and they get paid based
> on delivery without reimbursement for expenses. Driving a car is expensive,
> and finding parking is very hard. Delivery people who drive cars often lose
> money because they incur too many parking tickets. The delivery people have
> switched to battery-powered electric scooters and bicycles.
>
>
>
> These small electric vehicles are optimal for the delivery services since
> they can move around stopped traffic easily, and they can be brought inside
> the door of a building for a delivery, avoiding the risk of parking fines
> or the vehicle getting stolen. However, the batteries will only last for a
> few hours of use at most. The delivery people want the option of using the
> electric bicycle or scooter all day to try to make more money. The common
> solution is to remove the battery that came with the vehicle and replace it
> with a much larger after-market replacement. The delivery services do not
> pay well, so people look for the cheapest option they can find for a large
> battery. The regulations in the United States make it easy to order
> something online that has undergone no safety testing at all. The result is
> that a battery of dubious quality is placed in an electric bicycle by a
> person with dubious technical skills. No effort may have been made to match
> the charger with the battery. The battery may not be provided with the
> physical protection necessary to avoid damage during use. The question
> isn’t why there are so many fires, but why there aren’t more considering
> the circumstances.
>
>
>
> In the United States, there is reasonable indemnification of the test
> laboratories. The test laboratories accredited under the OSHA Nationally
> Recognized Test Laboratory (NRTL) system have a reasonable level of
> protection. If a product carrying one of their certification marks fails,
> they can be sued, but it would be hard for that law suit to make it to
> court. The test laboratories will indicate that they tested samples on a
> given date and found those samples to meet the technical requirements of
> the standard at that time. Their report does not state that the samples
> were safe. It only states that they passed testing of specific
> requirements. The legal system places the responsibility for safety onto
> the manufacturer.
>
>
>
> The challenges that I see are that battery manufacturers willing to ignore
> safety might be willing to forge safety certification marks and documents.
> I strongly suspect you can buy product online and have them shipped to the
> UK or Europe with a Declaration of Conformity based on nothing. I suspect
> manufacturers will claim their products meet requirements without testing
> or documentation to back it up. If the manufacturer is located outside of
> Europe and has no legal presence there, they can sell on line and avoid
> responsibility. I strongly suspect that this is why there are stricter
> requirements for online importers and distributors in the new GPSR.
>
>
>
> The overall issue is not new. Insufficient testing, forged or missing
> documentation, irresponsible actors shipping from the far side of the world
> and the other problems have existed for a while. However, the large size of
> the batteries in these scooters and bicycles, and the common charging of
> them indoors in buildings with a large number of residents, creates an
> issue where a failure can jeopardize many more lives in a single incident.
>
>
>
>
>
> Ted Eckert
>
>
>
> *The opinions expressed are my own and do not necessarily reflect those of
> my employer.*
>
>
>
> *From:* Matthew Wilson | GBE 
> *Sent:* Friday, July 28, 2023 2:11 AM
> *To:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Subject:* [EXTERNAL] [PSES] BBC news article re Li-ion batteries...
>
>
>
> I thought this news article that was on the BBC TV broadcast bulletins 27
> th July might be of interest.
>
>
>
> “Batteries for e-bikes should be regulated in the same way as fireworks,
> heavy machinery or medical devices because of the fire risk they pose, a
> charity [UK based Electrical Safety First] has said”
>
>
>
> 

Re: [PSES] BBC news article re Li-ion batteries...

[Scott Xe]

All new regulations address the issues from the online and offline stores.
Let's see how to improve the current situation.  Expecting the online
stores to implement it proves ineffective.  Hope the gap will be closed
soon.

Regards,

Scott


On Fri, 28 Jul 2023 at 22:05, Jim Bacher, WB8VSU  wrote:

> When I worked for a manufacturer, only two countries in Europe stopped
> shipments of products to confirm we had done the testing required to apply
> the CE Mark.
>
> I wouldn't be surprised to find out the products that had fires were
> bought online from sellers on eBay or similar online services.
>
> There are eBay sellers in China that sell products that are made by
> manufacturers who do not identify themselves. They tend to not have
> manuals, labels, etc.
>
> I recently bought two RF Power meters to test. One was about $32 and one
> was $98 (USA dollars). Neither of them had the manfacture identified, etc.
> Neither preformed very well against the  specifications the sellers were
> claiming.
>
> Single items being shipped in from China, bought online, will likely never
> be checked for certifications.
>
> Jim
>
>
>
> On July 28, 2023 5:23:22 AM Charlie Blackham 
> wrote:
>
>> Matthew
>>
>>
>>
>> I think the issue is, again, one of enforcement – the UK General Product
>> Safety Regulations impose requirements on both manufacturers and importers,
>> so there is existing legislation that could be used.
>>
>>
>>
>> Best regards
>>
>> Charlie
>>
>>
>>
>> *Charlie Blackham*
>>
>> *Sulis Consultants Ltd*
>>
>> *Tel: +44 (0)7946 624317*
>>
>> *Web: **https://sulisconsultants.com/* 
>>
>> Registered in England and Wales, number 05466247
>>
>>
>>
>> *From:* Matthew Wilson | GBE 
>> *Sent:* Friday, July 28, 2023 10:11 AM
>> *To:* EMC-PSTC@LISTSERV.IEEE.ORG
>> *Subject:* [PSES] BBC news article re Li-ion batteries...
>>
>>
>>
>> I thought this news article that was on the BBC TV broadcast bulletins 27
>> th July might be of interest.
>>
>>
>>
>> “Batteries for e-bikes should be regulated in the same way as fireworks,
>> heavy machinery or medical devices because of the fire risk they pose, a
>> charity [UK based Electrical Safety First] has said”
>>
>>
>>
>> https://www.bbc.co.uk/news/technology-66304564
>>
>>
>>
>>
>>
>> *Disclaimer:**​*
>>  This email and any files transmitted with it are confidential and intended 
>> solely for the use of the individual or entity to whom they are addressed.
>>
>> ​If you have received this email in error please delete it from your system, 
>> do not use or disclose the information in any way and notify the sender 
>> immediately.
>>
>> ​The contents of this message may contain personal views which are not the 
>> views of the company, unless specifically stated.
>> ​
>>
>> ​GB Electronics (UK) Ltd is a company registered in England and Wales under 
>> number 06210991.
>>
>> ​Registered office: Ascot House Mulberry Close, Woods Way, Goring By Sea, 
>> West Sussex, BN12 4QY.
>> --
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>>
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> This message is from the IEEE Product Safety 

Re: [PSES] BBC news article re Li-ion batteries...

[Scott Xe]

It happens before COVID-19 and becomes obvious due to more popular usage
during & post COVID-19.  As far as I recall, Amazon has taken down this
type of products from their websites and asked for test reports and DoC.
UL also supported the creation of a new set of standards for this type of
product.  Are the current regulatory and compliance standards ineffective
to bring safe products into the market?

Regards,

Scott


On Fri, 28 Jul 2023 at 17:11, Matthew Wilson | GBE <
matthew.wil...@gbelectronics.com> wrote:

> I thought this news article that was on the BBC TV broadcast bulletins 27
> th July might be of interest.
>
>
>
> “Batteries for e-bikes should be regulated in the same way as fireworks,
> heavy machinery or medical devices because of the fire risk they pose, a
> charity [UK based Electrical Safety First] has said”
>
>
>
> https://www.bbc.co.uk/news/technology-66304564
>
>
>
>
> Disclaimer:​
>  This email and any files transmitted with it are confidential and intended 
> solely for the use of the individual or entity to whom they are addressed.
>
> ​If you have received this email in error please delete it from your system, 
> do not use or disclose the information in any way and notify the sender 
> immediately.
>
> ​The contents of this message may contain personal views which are not the 
> views of the company, unless specifically stated.
> ​
>
> ​GB Electronics (UK) Ltd is a company registered in England and Wales under 
> number 06210991.
>
> ​Registered office: Ascot House Mulberry Close, Woods Way, Goring By Sea, 
> West Sussex, BN12 4QY.
> --
>
> This message is from the IEEE Product Safety Engineering Society emc-pstc
> discussion list. To post a message to the list, send your e-mail to All
> emc-pstc postings are archived and searchable on the web at:
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Re: [PSES] EU Machinery Regulation official version

[Scott Xe]

Dear Doug,

Thanks for your detailed explanation!  It seems the goods for the UK market
do not legally need to change to the new EU MR until an updated regulation
replacing the current one (old EU MD) is issued in the UK.

Best regards,

Scott


On Fri, 14 Jul 2023 at 09:13, Doug Nix  wrote:

> Hi Scott,
>
> Don’t I wish I could. At this point I’d need a well-tuned crystal ball. I
> don’t believe that the UK is quite sure where things will go.
>
> Since the UK is no longer a member of the EU, none of the law relating to
> the Machinery Regulation (MR) applies. For EU Members, the MR does not need
> to be transposed into national law like the directives did. It simply comes
> into force, and the members are expected to enforce it as written. But of
> for the UK? It’s anybody’s guess. They could stay with the MD since it’s
> already transposed into the The Supply of Machinery (Safety) Regulations
> 2008, UK SI 2008 No. 1597. They could modify UK SI 2008 No. 1597. They
> could lift the entire MR and adopt it as a new UK regulation.
>
> We’ll have to wait and see. As we get closer to the mandatory date they
> should start to tell people what they have in mind.
>
> My concern is that the new MR is considerably modernized, including
> clauses on AI and cybersecurity, and the former MD Annex IV list is gone,
> replaced with a more rational means of identifying dangerous machinery. If
> the UK stays with UK SI 2008 No. 1597, then they will be sliding backward
> compared to their closest neighbours. On the other hand, if they get a grip
> and decide to rejoin the EU as they likely should, then the new MR will
> come into force on the day they join.
>
> We shall see. Get your popcorn ready. It’s gonna be a wild ride I think.
>
> Best,
> Doug Nix
> d...@ieee.org
> +1 (519) 729-5704
>
> On Jul 13, 2023, at 21:04, Scott Xe  wrote:
>
>
> Dear Doug,
>>
>> Regarding the UK implementation part in your article, can you elaborate
>> the details of the UK implementation after the end of the transition date
>> of 31/12/2024?
>>
>> Thanks and regards,
>>
>> Scott
>>
>> On Thu, 6 Jul 2023 at 00:59,  wrote:
>>
>>> Thanks, Doug!
>>>
>>>
>>>
>>> Scott
>>>
>>>
>>>
>>> *From:* Doug Nix 
>>> *Sent:* Wednesday, July 5, 2023 2:24 AM
>>> *To:* Scott Xe 
>>> *Subject:* Re: [PSES] EU Machinery Regulation official version
>>>
>>>
>>>
>>> Hi Scott,
>>>
>>>
>>>
>>> If you are using the EM Machinery Regulation for CE Marking then, yes,
>>> of course it does. See articles 23 and 24 of the regulation.
>>>
>>>
>>>
>>> Doug Nix
>>> d...@ieee.org
>>> +1 (519) 729-5704
>>>
>>>
>>>
>>> On Jul 4, 2023, at 12:45, Scott Xe  wrote:
>>>
>>>
>>>
>>> Dear Doug,
>>>
>>>
>>>
>>> Many thanks for your brief and useful information!  I wonder if this
>>> regulation still requires a DoC.
>>>
>>>
>>>
>>> Best regards,
>>>
>>>
>>>
>>> Scott
>>>
>>>
>>>
>>>
>>>
>>
>

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Re: [PSES] EU Machinery Regulation official version

[Scott Xe]

> Dear Doug,
>
> Regarding the UK implementation part in your article, can you elaborate
> the details of the UK implementation after the end of the transition date
> of 31/12/2024?
>
> Thanks and regards,
>
> Scott
>
> On Thu, 6 Jul 2023 at 00:59,  wrote:
>
>> Thanks, Doug!
>>
>>
>>
>> Scott
>>
>>
>>
>> *From:* Doug Nix 
>> *Sent:* Wednesday, July 5, 2023 2:24 AM
>> *To:* Scott Xe 
>> *Subject:* Re: [PSES] EU Machinery Regulation official version
>>
>>
>>
>> Hi Scott,
>>
>>
>>
>> If you are using the EM Machinery Regulation for CE Marking then, yes, of
>> course it does. See articles 23 and 24 of the regulation.
>>
>>
>>
>> Doug Nix
>> d...@ieee.org
>> +1 (519) 729-5704
>>
>>
>>
>> On Jul 4, 2023, at 12:45, Scott Xe  wrote:
>>
>>
>>
>> Dear Doug,
>>
>>
>>
>> Many thanks for your brief and useful information!  I wonder if this
>> regulation still requires a DoC.
>>
>>
>>
>> Best regards,
>>
>>
>>
>> Scott
>>
>>
>>
>>
>>
>

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Re: [PSES] EU Machinery Regulation official version

[Scott Xe]

Dear Doug,

Many thanks for your brief and useful information!  I wonder if this
regulation still requires a DoC.

Best regards,

Scott

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[PSES] Safety shutters in BS 13A socket

[Scott Xe]

BS 13A sockets are designed with a safety shutter to prevent accidental
contact with live electrical contacts. According to the BS standard, the
shutters for the live (L) and neutral (N) apertures must block securely. Is
there any verification test available to ensure that the shutters for the L
and N apertures meet this required safety standard?

Thanks and regards,

Scott

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[PSES] Compliant needle-flame test material vs V-0 material

[Scott Xe]

According to EN 62368-1 : 2020 + A11 : 2020 - Cl 6.4.8.4

Smaller distances are allowed provided that the part of the fire enclosure
or fire barrier within
the required separation distance complies with one of the following:

• the fire enclosure or fire barrier meets the needle-flame test according
to IEC 60695-11-5. Severities are identified in Clause S.2. After the test,
the fire enclosure or fire barrier material shall not have formed any holes
that are bigger than allowed in 6.4.8.3.3 or 6.4.8.3.4 as appropriate; or
• the fire enclosure is made of V-0 class material; or
• the fire barrier is made of V-0 class material or VTM-0 class material.

The test house found that the fire enclosure material could not meet the
needle-flame test and considered non-compliance.  However, the supplier
claims that the fire enclosure is made of V-0 material meeting the 2nd
requirement.  Since the verification methods and conditions of needle-flame
test and UL 94 are not identical, is it possible the V-0 material does not
meet the needle-flame test?

Thanks and regards,

Scott

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Re: [PSES] Interesting material

[scott . xe]

Dear Doug,

 

Very interesting!  I am aware of humidity level that affects the insulation.  
Thanks for your experiments that show the spark as well.  If the humidity would 
affect the leakage current, I do not notice the standard gives the humidity 
condition for the current measurement.  Is there any default condition applied?

 

Regards,

 

Scott

 

From: doug emcesd.com  
Sent: Saturday, February 18, 2023 3:00 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Interesting material

 

Here is a better video where I limit the applied voltage to a reasonable 
operating voltage to just see the humidity effect.

 

https://www.dropbox.com/s/t1udll2dqidl8o7/VID_20230217_205517.mp4?dl=0

 

Doug Smith

Sent from my iPhone

IPhone: 408-858-4528

Office: 702-570-6108

Email: d...@dsmith.org  

Website: http://dsmith.org

  _  

From: doug emcesd.com
Sent: Friday, February 17, 2023 10:54:10 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG   
mailto:EMC-PSTC@LISTSERV.IEEE.ORG> >; 
si-l...@freelists.org   mailto:si-l...@freelists.org> >
Subject: Interesting material 

 

Hi All,

 

I was testing a new material for a different purpose and accidentally found 
that it was very sensitive to humidity/moisture. Might make a good humidity 
alarm for an industrial process or other application. What do you think? Here 
is a short video:

 

https://www.dropbox.com/s/1bhp7mn2l4e24n0/VID_20230209_155921.mp4?dl=0

 

Doug Smith

Sent from my iPhone

IPhone: 408-858-4528

Office: 702-570-6108

Email: d...@dsmith.org  

Website: http://dsmith.org

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Re: [PSES] EN 62368-1 : 2014

[Scott Xe]

Dear All,

Thanks for your comments!  It said version 4 will be issued in 2023 and
hope there is less chance to have amendments during the extension period.

Best regards,

Scott

On Thu, 8 Dec 2022 at 00:42, Scott Xe  wrote:

> CENELEC recently extended DoW for 18 months from 06/01/2023 to
> 06/07/2024.  What are the impacts on importers/manufacturers, test houses
> and market surveillances?
>
> EN 62368-1 : 2014 is still valid for LVD/RED in EUOJ.  All the relevant
> products should follow this version for EU markets.  What is the point of
> this change to them?
>
> In general the test houses give unclear interpretations to their clients
> in this aspect.  Sometimes, they follow EUOJ requirements but sometimes
> CENELEC.  Some importers/manufacturers also confuse which requirements to
> follow.  Some countries also may not adopt the latest IEC/EN standard as
> their national standards.  Can't withdrawn standards be used?
>
> Thanks and best regards,
>
> Scott
>

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[PSES] EN 62368-1 : 2014

[Scott Xe]

CENELEC recently extended DoW for 18 months from 06/01/2023 to 06/07/2024.
What are the impacts on importers/manufacturers, test houses and market
surveillances?

EN 62368-1 : 2014 is still valid for LVD/RED in EUOJ.  All the relevant
products should follow this version for EU markets.  What is the point of
this change to them?

In general the test houses give unclear interpretations to their clients
in this aspect.  Sometimes, they follow EUOJ requirements but sometimes
CENELEC.  Some importers/manufacturers also confuse which requirements to
follow.  Some countries also may not adopt the latest IEC/EN standard as
their national standards.  Can't withdrawn standards be used?

Thanks and best regards,

Scott

-

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discussion list. To post a message to the list, send your e-mail to 


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Re: [PSES] Regulation vs Directive

[Scott Xe]

Hi Charlie,

Thanks for the explanation!  It seems the importers and manufacturers do
not have much differences to implement the law accordingly.

Regards,

Scott


On Wed, 7 Dec 2022 at 00:09, Charlie Blackham 
wrote:

> Scott
>
>
>
> A Directive has to be transposed into the law of each member state
>
>
>
> A Regulation applies without the need to do this
>
>
>
> Types of legislation (europa.eu)
> <https://european-union.europa.eu/institutions-law-budget/law/types-legislation_en>
>
>
>
> The EU is moving towards Regulations as they are binding without member
> states needing to implement national law
>
>
>
> Best regards
>
> Charlie
>
>
>
> *Charlie Blackham*
>
> *Sulis Consultants Ltd*
>
> *Tel: +44 (0)7946 624317*
>
> *Web: https://sulisconsultants.com/ <https://sulisconsultants.com/> *
>
> Registered in England and Wales, number 05466247
>
>
>
> *From:* Scott Xe 
> *Sent:* 06 December 2022 15:51
> *To:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Subject:* [PSES] Regulation vs Directive
>
>
>
> Dear All,
>
>
>
> Some of the new proposals of Directive change the Directive to Regulation
> such as General Product Safety Regulation, Packaging and Packaging Waste
> Regulation, Portable battery regulation, etc, .  What are the key
> differences between Regulation and Directive?
>
>
>
> Thanks and regards,
>
>
>
> Scott
>
> -
> 
>
> This message is from the IEEE Product Safety Engineering Society emc-pstc
> discussion list. To post a message to the list, send your e-mail to <
> emc-p...@ieee.org>
>
> All emc-pstc postings are archived and searchable on the web at:
> http://www.ieee-pses.org/emc-pstc.html
>
> Website: http://www.ieee-pses.org/
> Instructions: http://www.ieee-pses.org/list.html (including how to
> unsubscribe) <http://www.ieee-pses.org/list.html>
> List rules: http://www.ieee-pses.org/listrules.html
>
> For help, send mail to the list administrators:
> Mike Cantwell 
>
> For policy questions, send mail to:
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> David Heald 
> --
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[PSES] Regulation vs Directive

[Scott Xe]

Dear All,

Some of the new proposals of Directive change the Directive to Regulation
such as General Product Safety Regulation, Packaging and Packaging Waste
Regulation, Portable battery regulation, etc, .  What are the key
differences between Regulation and Directive?

Thanks and regards,

Scott

-

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Re: [PSES] Link to secondary legislation draft RE: [PSES] SI amendment providing UKCA label deadline extension.

[Scott Xe]

Lauren, tks for sharing!

Cheers,

Scott

On Wed, 16 Nov 2022 at 23:41, Lauren Crane <
1afd08519f18-dmarc-requ...@listserv.ieee.org> wrote:

> Hello All,
>
>
>
> In case you are interested in seeing it is more concretely true, here is a
> link to the secondary legislation laid before parliament that is a proposal
> to modify many (most/all) of the UKCA SI’s with the extended date. Click on
> “full wording” top left, to see the draft.
>
>
>
> https://statutoryinstruments.parliament.uk/instrument/Iej3CpFt/
>
>
>
> Best Regards,
>
> -Lauren
>
> LAM RESEARCH CONFIDENTIALITY NOTICE: This e-mail transmission, and any
> documents, files, or previous e-mail messages attached to it,
> (collectively, "E-mail Transmission") may be subject to one or more of the
> following based on the associated sensitivity level: E-mail Transmission
> (i) contains confidential information, (ii) is prohibited from distribution
> outside of Lam, and/or (iii) is intended solely for and restricted to the
> specified recipient(s). If you are not the intended recipient, or a person
> responsible for delivering it to the intended recipient, you are hereby
> notified that any disclosure, copying, distribution or use of any of the
> information contained in or attached to this message is STRICTLY
> PROHIBITED. If you have received this transmission in error, please
> immediately notify the sender and destroy the original transmission and its
> attachments without reading them or saving them to disk. Thank you.
>
> Confidential – Limited Access and Use
> -
> 
>
> This message is from the IEEE Product Safety Engineering Society emc-pstc
> discussion list. To post a message to the list, send your e-mail to 
> emc-p...@ieee.org
>
> All emc-pstc postings are archived and searchable on the web at:
> http://www.ieee-pses.org/emc-pstc.html
>
> Website: http://www.ieee-pses.org/
> Instructions: http://www.ieee-pses.org/list.html (including how to
> unsubscribe) 
> List rules: http://www.ieee-pses.org/listrules.html
>
> For help, send mail to the list administrators:
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>
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> --
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Re: [PSES] SI amendment providing UKCA label deadline extension.

[Scott Xe]

Thanks for clarification.  Do they take effect immediately?


On Tue, 15 Nov 2022 at 12:51,  wrote:

> The June proposal had similarities, but the difference between now and
> June is that the June proposal was to allow UKCA markings alternatively on
> the accompanying documents whereas this proposal extends recognition of the
> CE marking.
>
> Regards,
>
> *Tom Smith, P.Eng *
>
>
> *Principal EngineerTJS Technical Services Inc.*
>
> Tel: +1 403-612-6664
>
> Email: tsm...@tjstechnical.com
> http://tjstechnical.com
>
> Follow us on Twitter: TJS_Technical
>
>
>
> *From:* Scott Xe 
> *Sent:* November 14, 2022 9:17 PM
> *To:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Subject:* Re: [PSES] SI amendment providing UKCA label deadline
> extension.
>
>
>
> Hi Charlie,
>
>
>
> Yes, it is not a brand new extension as it was mentioned in June this
> year.  Hope it amends the SI shortly.
>
>
>
> Regards,
>
>
>
> Scott
>
>
>
>
>
> On Tue, 15 Nov 2022 at 01:44, Charlie Blackham <
> char...@sulisconsultants.com> wrote:
>
> All
>
>
>
> This relaxation has been trailed / announced, but it is not law until the
> Statutory Instrument has been published on https://www.legislation.gov.uk/
> (it’s not there at time of typing)
>
>
>
> Best regards
>
> Charlie
>
>
>
> *Charlie Blackham*
>
> *Sulis Consultants Ltd*
>
> *Tel: +44 (0)7946 624317*
>
> *Web: https://sulisconsultants.com/ <https://sulisconsultants.com/> *
>
> Registered in England and Wales, number 05466247
>
>
>
> *From:* Tom Smith 
> *Sent:* 14 November 2022 17:37
> *To:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Subject:* Re: [PSES] SI amendment providing UKCA label deadline
> extension.
>
>
>
> An announcement was made this morning extending allowance for using the CE
> marking for an additional 2 years until Dec 31, 2024.
>
>
> https://www.gov.uk/government/news/businesses-to-be-given-uk-product-marking-flexibility
>
> Regards,
>
> *Tom Smith, P.Eng *
>
>
> *Principal EngineerTJS Technical Services Inc.*
>
> Tel: +1 403-612-6664
>
> Email: tsm...@tjstechnical.com
> http://tjstechnical.com
>
> Follow us on Twitter: TJS_Technical
>
>
>
> *From:* Scott Xe 
> *Sent:* November 14, 2022 9:30 AM
> *To:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Subject:* Re: [PSES] SI amendment providing UKCA label deadline
> extension.
>
>
>
> Dear Scott & Lauren,
>
>
>
> Today, I received the following info to supplement the above development.
>
>
>
> *"Some news from the Department for Business, Energy and Industrial
> Strategy (BEIS):-*
>
>
>
> *HMG intends to introduce legislation to continue recognition of the CE
> marking and reversed epsilon marking until 31 December 2024 for most goods
> being placed on the market or put into service in Great Britain as part of
> new ministers’ commitment to reduce burdens for industry.*
>
>
>
> *This package of measures is intended to provide businesses with more
> flexibility and reduce burdens for businesses. We will use our regulatory
> autonomy to help businesses navigate the current global economic and supply
> chain challenges whilst prioritising growth.   *
>
> * In parallel, we will also consider how we could reduce costs and burdens
> associated with the UK regulatory framework in the longer-term, including
> opportunities under the Product Safety Review. *
>
>
>
> *We also intend to introduce legislation to give effect to the measures
> previously announced in June 2022 with amended timescales, in line with the
> extension.  These measures intend to: *
>
>
>
> *• Reduce labelling costs by continuing to allow businesses to
> affix the UKCA marking, and to include importer information for products
> from EEA countries (and in some cases, Switzerland) on an accompanying
> document or a label until 31 December 2027. *
>
>
>
> *• Reduce re-testing costs for UKCA certification by allowing
> conformity assessment activities for CE marking undertaken by 31 December
> 2024 to be used by manufacturers as the basis for UKCA marking, until the
> expiry of the certificate or until 31 December 2027, whichever is sooner."*
>
>
>
> Cheers,
>
>
>
> Scott
>
>
>
> On Sat, 12 Nov 2022 at 05:55, Scott Aldous <
> 0220f70c299a-dmarc-requ...@listserv.ieee.org> wrote:
>
> Hi Lauren,
>
>
>
> It's a good question. A draft amendment was published on 6 September to
> effect the extension, but the draft was withdrawn on 10 October, stating
> that "a new version will be publis

Re: [PSES] SI amendment providing UKCA label deadline extension.

[Scott Xe]

Hi Charlie,

Yes, it is not a brand new extension as it was mentioned in June this
year.  Hope it amends the SI shortly.

Regards,

Scott


On Tue, 15 Nov 2022 at 01:44, Charlie Blackham 
wrote:

> All
>
>
>
> This relaxation has been trailed / announced, but it is not law until the
> Statutory Instrument has been published on https://www.legislation.gov.uk/
> (it’s not there at time of typing)
>
>
>
> Best regards
>
> Charlie
>
>
>
> *Charlie Blackham*
>
> *Sulis Consultants Ltd*
>
> *Tel: +44 (0)7946 624317*
>
> *Web: https://sulisconsultants.com/ <https://sulisconsultants.com/> *
>
> Registered in England and Wales, number 05466247
>
>
>
> *From:* Tom Smith 
> *Sent:* 14 November 2022 17:37
> *To:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Subject:* Re: [PSES] SI amendment providing UKCA label deadline
> extension.
>
>
>
> An announcement was made this morning extending allowance for using the CE
> marking for an additional 2 years until Dec 31, 2024.
>
>
> https://www.gov.uk/government/news/businesses-to-be-given-uk-product-marking-flexibility
>
> Regards,
>
> *Tom Smith, P.Eng *
>
>
> *Principal Engineer TJS Technical Services Inc.*
>
> Tel: +1 403-612-6664
>
> Email: tsm...@tjstechnical.com
> http://tjstechnical.com
>
> Follow us on Twitter: TJS_Technical
>
>
>
> *From:* Scott Xe 
> *Sent:* November 14, 2022 9:30 AM
> *To:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Subject:* Re: [PSES] SI amendment providing UKCA label deadline
> extension.
>
>
>
> Dear Scott & Lauren,
>
>
>
> Today, I received the following info to supplement the above development.
>
>
>
> *"Some news from the Department for Business, Energy and Industrial
> Strategy (BEIS):-*
>
>
>
> *HMG intends to introduce legislation to continue recognition of the CE
> marking and reversed epsilon marking until 31 December 2024 for most goods
> being placed on the market or put into service in Great Britain as part of
> new ministers’ commitment to reduce burdens for industry.*
>
>
>
> *This package of measures is intended to provide businesses with more
> flexibility and reduce burdens for businesses. We will use our regulatory
> autonomy to help businesses navigate the current global economic and supply
> chain challenges whilst prioritising growth.   *
>
> * In parallel, we will also consider how we could reduce costs and burdens
> associated with the UK regulatory framework in the longer-term, including
> opportunities under the Product Safety Review. *
>
>
>
> *We also intend to introduce legislation to give effect to the measures
> previously announced in June 2022 with amended timescales, in line with the
> extension.  These measures intend to: *
>
>
>
> *• Reduce labelling costs by continuing to allow businesses to
> affix the UKCA marking, and to include importer information for products
> from EEA countries (and in some cases, Switzerland) on an accompanying
> document or a label until 31 December 2027. *
>
>
>
> *• Reduce re-testing costs for UKCA certification by allowing
> conformity assessment activities for CE marking undertaken by 31 December
> 2024 to be used by manufacturers as the basis for UKCA marking, until the
> expiry of the certificate or until 31 December 2027, whichever is sooner."*
>
>
>
> Cheers,
>
>
>
> Scott
>
>
>
> On Sat, 12 Nov 2022 at 05:55, Scott Aldous <
> 0220f70c299a-dmarc-requ...@listserv.ieee.org> wrote:
>
> Hi Lauren,
>
>
>
> It's a good question. A draft amendment was published on 6 September to
> effect the extension, but the draft was withdrawn on 10 October, stating
> that "a new version will be published in due course". More information
> here
> <https://www.gov.uk/eu-withdrawal-act-2018-statutory-instruments/the-product-safety-and-metrology-amendment-regulations-2022>
> .
>
>
>
> ExVeritas published an article on this on 3 November (in the context of
> ATEX Directive but generally applicable). You can find that article here
> <https://www.exveritas.com/2022/11/03/proposed-ukca-ex-atex-legislation-changes-withdrawn/>.
> Unfortunately the article doesn't give much more information.
>
>
>
> On Wed, Nov 9, 2022 at 11:14 AM Lauren Crane <
> 1afd08519f18-dmarc-requ...@listserv.ieee.org> wrote:
>
> Hello All,
>
>
>
> Among all the UKCA discussion I have not noticed information on whether
> the promised no-label extension to 2026, though promised on government
> websites, is actually in the works with hope of becoming law before Jan 1,
> 2023.
>
>
>
> Does anyo

Re: [PSES] SI amendment providing UKCA label deadline extension.

[Scott Xe]

Dear Scott & Lauren,

Today, I received the following info to supplement the above development.

*"Some news from the Department for Business, Energy and Industrial
Strategy (BEIS):-*

*HMG intends to introduce legislation to continue recognition of the CE
marking and reversed epsilon marking until 31 December 2024 for most goods
being placed on the market or put into service in Great Britain as part of
new ministers’ commitment to reduce burdens for industry.*

*This package of measures is intended to provide businesses with more
flexibility and reduce burdens for businesses. We will use our regulatory
autonomy to help businesses navigate the current global economic and supply
chain challenges whilst prioritising growth.   *
* In parallel, we will also consider how we could reduce costs and burdens
associated with the UK regulatory framework in the longer-term, including
opportunities under the Product Safety Review. *

*We also intend to introduce legislation to give effect to the measures
previously announced in June 2022 with amended timescales, in line with the
extension.  These measures intend to: *

*• Reduce labelling costs by continuing to allow businesses to affix the
UKCA marking, and to include importer information for products from EEA
countries (and in some cases, Switzerland) on an accompanying document or a
label until 31 December 2027. *

*• Reduce re-testing costs for UKCA certification by allowing conformity
assessment activities for CE marking undertaken by 31 December 2024 to be
used by manufacturers as the basis for UKCA marking, until the expiry of
the certificate or until 31 December 2027, whichever is sooner."*

Cheers,

Scott

On Sat, 12 Nov 2022 at 05:55, Scott Aldous <
0220f70c299a-dmarc-requ...@listserv.ieee.org> wrote:

> Hi Lauren,
>
> It's a good question. A draft amendment was published on 6 September to
> effect the extension, but the draft was withdrawn on 10 October, stating
> that "a new version will be published in due course". More information
> here
> 
> .
>
> ExVeritas published an article on this on 3 November (in the context of
> ATEX Directive but generally applicable). You can find that article here
> .
> Unfortunately the article doesn't give much more information.
>
> On Wed, Nov 9, 2022 at 11:14 AM Lauren Crane <
> 1afd08519f18-dmarc-requ...@listserv.ieee.org> wrote:
>
>> Hello All,
>>
>>
>>
>> Among all the UKCA discussion I have not noticed information on whether
>> the promised no-label extension to 2026, though promised on government
>> websites, is actually in the works with hope of becoming law before Jan 1,
>> 2023.
>>
>>
>>
>> Does anyone have information on this point?
>>
>>
>>
>> Best Regards,
>>
>> -Lauren
>>
>>
>>
>> LAM RESEARCH CONFIDENTIALITY NOTICE: This e-mail transmission, and any
>> documents, files, or previous e-mail messages attached to it,
>> (collectively, "E-mail Transmission") may be subject to one or more of the
>> following based on the associated sensitivity level: E-mail Transmission
>> (i) contains confidential information, (ii) is prohibited from distribution
>> outside of Lam, and/or (iii) is intended solely for and restricted to the
>> specified recipient(s). If you are not the intended recipient, or a person
>> responsible for delivering it to the intended recipient, you are hereby
>> notified that any disclosure, copying, distribution or use of any of the
>> information contained in or attached to this message is STRICTLY
>> PROHIBITED. If you have received this transmission in error, please
>> immediately notify the sender and destroy the original transmission and its
>> attachments without reading them or saving them to disk. Thank you.
>>
>> Confidential – Limited Access and Use
>> -
>> 
>>
>> This message is from the IEEE Product Safety Engineering Society emc-pstc
>> discussion list. To post a message to the list, send your e-mail to 
>> emc-p...@ieee.org
>>
>> All emc-pstc postings are archived and searchable on the web at:
>> http://www.ieee-pses.org/emc-pstc.html
>>
>> Website: http://www.ieee-pses.org/
>> Instructions: http://www.ieee-pses.org/list.html (including how to
>> unsubscribe) 
>> List rules: http://www.ieee-pses.org/listrules.html
>>
>> For help, send mail to the list administrators:
>> Mike Cantwell mcantw...@ieee.org
>>
>> For policy questions, send mail to:
>> Jim Bacher j.bac...@ieee.org
>> David Heald dhe...@gmail.com
>> --
>>
>> To unsubscribe from the EMC-PSTC list, click the following link:
>> https://listserv.ieee.org/cgi-bin/wa?SUBED1=EMC-PSTC=1
>>
>
>
> --
> Scott Aldous | Regulatory Compliance Manager | scottald...@google.com |
>  650-253-1994
>

Re: [PSES] EU harmonised standard of EN 62368-1 Ed3 : 2020 for General Product Safety Directive

[Scott Xe]

Dear Mike,

Appreciate your spotting out the essential part that was over-looked.  As
explained in above reply, it seems a full version of EN 62368-1 : 2020 is
still applied.  Did EU remove the transitional period for any
updates/amendments recently?  From now on, all listed standards take effect
immediately.

Regarding the development of EN 62368-1, the 3rd edition likely skips in
LVD and RED.  We are awaiting further detail about the 4th edition in 2023.

Thanks and regards,

Scott

On Wed, 2 Nov 2022 at 00:56, MIKE SHERMAN  wrote:

> Scott --
>
> Go to page 63 of the OJ from August 16
>
> https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=OJ:L:2022:213:FULL=EN
> and look at item 21
> “However, the publication of those references should be limited to the
> clauses 3.3.19 ‘Sound exposure’ and 10.6 ‘Safeguard against acoustic energy
> sources’, given that the purpose of Commission Decision 2009/490/EC is
> limited to ensuring that exposure to sound from personal music players does
> not pose a risk to hearing.”
> So it looks like this is a very limited adoption of only PART of the third
> edition for the sole purpose of personal music players.
>
> Here also is some information about 62368-1 that I gleaned from the IEEE
> ISPCE Symposium in San Diego in September:
> -2nd edition: has a "dow" Date of Withdrawal of January 2023; reportedly
> there is a CENELC vote going on right now to extend that (18 months?) so it
> can continue to be valid as we wait for the 4th edition
> -3rd edition is still dead [as a harmonized standard for LVD]
> -4th edition is being voted on, perhaps in January 2023, and so may soon
> be approved simultaneously by both IEC and CENELEC. Reportedly the
> committee has been working closely with the EU to avoid the problems that
> sunk the 3rd edition as a viable harmonized EN standard.
>
> Mike Sherman
> Sherman PSC LLC
>
> On 11/01/2022 9:45 AM Scott Xe  wrote:
>
>
> Dear All,
>
> On 16 Aug 2022, OJEU listed EN 62368-1 2020 without a deadline of an
> enforcement date.  Normally it will have a transitional period of 18 or 24
> months.  Does it mean to take effect immediately without a transitional
> period from EN 62368-1 Ed2 : 2014 to EN 62368-1 Ed 3 : 2020?
>
>
> Thanks and regards,
>
> Scott
> -
> 
>
> This message is from the IEEE Product Safety Engineering Society emc-pstc
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> emc-p...@ieee.org>
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Re: [PSES] EU harmonised standard of EN 62368-1 Ed3 : 2020 for General Product Safety Directive

[Scott Xe]

Hi Charlie,

You are right the edition 2 has not been listed in GPSD.  The 2022/1401
decision amending 2019/1698 decision states that row 66 and 67 are replaced
by EN IEC 62368-1 : 2020 and EN IEC 62368-1 : 2020/A11 : 2020.  The row 66
and 67 of 2019/1698 are referenced to EN 60065 and 60950-1.  Thus they are
repealed.

I might over interpreted the decision to make the product in compliance
with full EN 62368-1 Ed3 : 2020 standard.  Thanks for your guidance!  At
least, it may meet EN 60065 or 60950-1 depending on product type plus
clauses 3.3.19 ‘Sound exposure’ and 10.6 ‘Safeguard against acoustic energy
sources’.  Since both EN 60065 and 60950-1 have been replaced with EN
62368-1 : 2020, should the conformity test use a full version of EN 62368-1
: 2020 instead of 2 clauses only?

Cheers!

Scott

On Wed, 2 Nov 2022 at 00:39, Charlie Blackham 
wrote:

> Scott
>
>
>
> I’m fairly certain that EN 62368-1:2014 was never listed under the GPSD –
> only the LVD – 60065 and 60950 remained listed.
>
>
>
> The listing of the 2020 version of 62368-1 is accompanied by the following
> “whereas”:
>
>
> By letter M/452 of 28 September 2009, the Commission made a request to the
> European Committee for Electrotechnical Standardization (‘Cenelec’) to draw
> up European standards for personal music players. On the basis of this
> request, Cenelec adopted standard EN IEC 62368-1:2020 on ‘Audio/video,
> information and communication technology equipment – Part 1: Safety
> requirements’ and, further to that, the amendment EN IEC
> 62368-1:2020/A11:2020. EN IEC 62368-1:2020 is proposed with its amendment
> A11:2020, which complies with the general safety requirement set out in
> Directive 2001/95/EC. Its reference should be published in the *Official
> Journal of the European Union* replacing the references EN 60065:2002
> ‘Audio, video and similar electronic apparatus – Safety requirements’ and
> EN 60950-1:2006 ‘Information technology equipment – Safety -- Part 1:
> General requirements’. However, the publication of those references should
> be limited to the clauses 3.3.19 ‘Sound exposure’ and 10.6 ‘Safeguard
> against acoustic energy sources’, given that the purpose of Commission
> Decision 2009/490/EC is limited to ensuring that exposure to sound from
> personal music players does not pose a risk to hearing.
>
>
>
> And the listing states
>
> *Notice: this publication concerns only clauses 3.3.19 “Sound exposure”
> and 10.6 “Safeguard against acoustic energy sources” of EN IEC
> 62368-1:2020/A11:2020.*
>
>
>
> Best regards
>
> Charlie
>
>
>
> *Charlie Blackham*
>
> *Sulis Consultants Ltd*
>
> *Tel: +44 (0)7946 624317*
>
> *Web: https://sulisconsultants.com/ <https://sulisconsultants.com/> *
>
> Registered in England and Wales, number 05466247
>
>
>
> *From:* Scott Xe 
> *Sent:* 01 November 2022 14:45
> *To:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Subject:* [PSES] EU harmonised standard of EN 62368-1 Ed3 : 2020 for
> General Product Safety Directive
>
>
>
> Dear All,
>
>
>
> On 16 Aug 2022, OJEU listed EN 62368-1 2020 without a deadline of an
> enforcement date.  Normally it will have a transitional period of 18 or 24
> months.  Does it mean to take effect immediately without a transitional
> period from EN 62368-1 Ed2 : 2014 to EN 62368-1 Ed 3 : 2020?
>
>
>
> Thanks and regards,
>
> Scott
>
> -
> 
>
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> emc-p...@ieee.org>
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[PSES] EU harmonised standard of EN 62368-1 Ed3 : 2020 for General Product Safety Directive

[Scott Xe]

Dear All,

On 16 Aug 2022, OJEU listed EN 62368-1 2020 without a deadline of an
enforcement date.  Normally it will have a transitional period of 18 or 24
months.  Does it mean to take effect immediately without a transitional
period from EN 62368-1 Ed2 : 2014 to EN 62368-1 Ed 3 : 2020?


Thanks and regards,

Scott

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Re: [PSES] A11 : 2017 to HS EN 62368-1 : 2014 Ed2

[Scott Xe]

Dear Dürrer,

Thanks for your reply!  Probably my memory does not work well.  I read A11
in DoCs a few years ago but observed missed out in recent DoCs.  You are
right EU OJ does not list it in LVD and RED.

Regards,

Scott

On Fri, 28 Oct 2022 at 14:33, Dürrer Bernd  wrote:

> Hi Scott,
>
>
>
> I do not remember that EN 62368-1:2014/A11:2017 has ever been cited in the
> OJEU. Please check the CENELEC website CENELEC - CLC/TC 108X
> (cencenelec.eu)
> <https://standards.cencenelec.eu/dyn/www/f?p=CENELEC:110:FSP_PROJECT,FSP_ORG_ID:64228,1257189=1D04208AEAC83B2ED70B2788A8910D4F4>:
> “No citation expected for Directive 2001/95/EC, No citation expected for
> Directive 2014/35/EU, No citation expected for Directive 2014/53/EU”.
> According to the information given there, this amendment has been
> superseded by EN IEC 62368-1 (CENELEC - CLC/TC 108X (cencenelec.eu)
> <https://standards.cencenelec.eu/dyn/www/f?p=CENELEC:110:0FSP_PROJECT:67625=1D3126095A0F656DE1D5395E526F2F4AA>
> ).
>
>
>
> Kind regards,
>
>
>
> Bernd
>
>
>
> *Von:* Scott Xe 
> *Gesendet:* Donnerstag, 27. Oktober 2022 16:49
> *An:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Betreff:* [PSES] A11 : 2017 to HS EN 62368-1 : 2014 Ed2
>
>
>
> Dear Folks,
>
>
>
> Has this amendment been withdrawn from OJEU?  I remember it was in the
> list but check the latest summary list in OJEU and failed to find it.
>
>
>
> Thanks in advance!
>
>
>
> Scott
>
> -
> 
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[PSES] A11 : 2017 to HS EN 62368-1 : 2014 Ed2

[Scott Xe]

Dear Folks,

Has this amendment been withdrawn from OJEU?  I remember it was in the list
but check the latest summary list in OJEU and failed to find it.

Thanks in advance!

Scott

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Re: [PSES] Assess risk of electric shock from charged capacitors

[Scott Xe]

In order to judge if there is no risk of electric shock from charged
capacitors, it is required to measure the voltage across L and N of mains
plug after the removal of power input.  To avoid grounding loop between
test equipment and the unit under test, an isolating transformer is
strongly recommended.  I have learnt another way by using Add Function and
two hot probes of a dual channel DSO.  Can someone advise which way is more
common in safety conformity test.  Especially the latter one, I have not
tried it yet before and appreciate any notes I must take in the measurement.

Thanks and regards,

Scott

>

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Re: [PSES] EN 62368-1 Ed 3 2020 + A11 : 2020 for GPSD

[Scott Xe]

Hi Gert,

Unlike LVD & RED, there is no transitional date in GPSD HS table.   If
there is no transitional period, how can the manufacturers handle the goods
in the warehouse of the market and manufacturing plants to upgrade to new
standards?  Besides, what are the arrangements of goods in the water and
recent imported goods at customs and market surveillance with old standard
compliance?

Regards,

Scott

On Wed, 31 Aug 2022 at 01:03, Gert Gremmen  wrote:

> Hi Scott
>
> The OJ itself lists the required dates in he table of publication.
>
> Gert Gremmen
> On 30-8-2022 15:41, Scott Xe wrote:
>
> On 16 Aug, the captioned HS was listed in OJ.  Does it replace the
> previous version immediately or is there a transitional period?
>
> Thanks and regards,
>
> Scott
> -
> 
>
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[PSES] EN 62368-1 Ed 3 2020 + A11 : 2020 for GPSD

[Scott Xe]

On 16 Aug, the captioned HS was listed in OJ.  Does it replace the previous
version immediately or is there a transitional period?

Thanks and regards,

Scott

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[PSES] Design benefits for Class 1 appliances without an access earth point

[Scott Xe]

In general, the Class 1 appliances have metal enclosure whereas Class 2
have plastic enclosure.  There is a small group of products that are Class
1 without an access earth point, i.e. shredding machines, desktop fans,
laptop/monitor power suppliers, etc.  What are the real benefits from such
design as compared with Class 2 design?

Thanks and regards,

Scott

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Re: [PSES] Harmonised standards

[Scott Xe]

Hi Brian,

Good explanation!  We use the method #1 that to be interpreted correctly by
most of readers.  The symbol of forward slash means the only amendment may
not be known by all.

On Thu, 25 Aug 2022 at 03:49, Brian Kunde  wrote:

> This topic goes a little deeper, I think.  Question being, how are the
> harmonized standards to be listed on your DoC?
>
> It appears to me that the Commission lists standards a couple different
> ways, which adds to the confusion. For example, on the EMCD Harmonized
> Standards list, it shows it one way as:
>
> Method #1
> EN 16361:2013+A1:2016
>
> but then for another standard shows it this way:
>
> Method #2
> EN 50065-2-1:2003, EN 50065-2-1:2003/A1:2005, EN 50065-2-1:2003/AC:2003
>
> Using the first method, the above could be listed as
>
> Method #1
> EN 50065-2-1:2003+AC:2033+A1:2005
>
> I thought we had a discussion a year or so ago where the plus sign "+" was
> to be replaced by the slash "/".  If that is true, then the above could be
> listed as:
>
> Method #3
> EN 50065-2-1:2003/AC:2033/A1:2005
>
> But this method could be technically confusing thinking you are using only
> the amendment to show compliance. Yet, we all know what
> this really means, right?.
>
> So, which is correct?  Does it really matter?  Using method #2 above is
> probably the most correct, but it is very long.  I prefer method #1 or #3
> because it is shorter and gets the point across.
>
> Comments?
>
> The Other Brian
>
>
>
>
>
>
> On Wed, Aug 24, 2022 at 11:59 AM Scott Xe  wrote:
>
>> Hi Gert,
>>
>> Thanks for your useful reply!  The EN 55032 : 2017/A11 : 2020 contains
>> the corrigendum only, no any technical changes.  Does AC have another
>> condition to qualify for?
>>
>> Will arrange some time for visiting the CENELEC site.
>>
>> Best regards,
>>
>> Scott
>>
>> On Wed, 24 Aug 2022 at 21:38, Gert Gremmen  wrote:
>>
>>> Hi Scott,
>>>
>>> No only the :
>>>
>>> EN 55032 : 2017  is the Harmonised Standard (1 documnet)
>>> EN 55032 : 2017/A11 : 2020  is the (Harmonised) amendment only (1
>>> dcoument)
>>>
>>> Both documents are needed. (did not check the OJ for you)
>>>
>>> EN 55032 : 2017+A11 : 2020  is both documents together.
>>>
>>> AC stands for Corrigendum, most used for plain error, typos ,wrong
>>> references etc.
>>>
>>> There is lots of info on the site of CENELEC on these subjects. Worth so
>>> spent an afternoon.
>>>
>>> Gert Gremmen
>>>
>>> On 24-8-2022 15:06, Scott Xe wrote:
>>> > EN 55032 : 2017/A11 : 2020
>>> >
>>> --
>>> Independent Expert on CE marking
>>> EMC Consultant
>>> Electrical Safety Consultant
>>>
>>> -
>>> 
>>> This message is from the IEEE Product Safety Engineering Society
>>> emc-pstc discussion list. To post a message to the list, send your e-mail
>>> to 
>>>
>>> All emc-pstc postings are archived and searchable on the web at:
>>> http://www.ieee-pses.org/emc-pstc.html
>>>
>>> Website:  http://www.ieee-pses.org/
>>> Instructions:  http://www.ieee-pses.org/list.html (including how to
>>> unsubscribe)
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>>> _
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>>>
>> -
>> 
>>
>> This message is from the IEEE Product Safety Engineering Society emc-pstc
>> discussion list. To post a message to the list, send your e-mail to 
>> emc-p...@ieee.org
>>
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Re: [PSES] Harmonised standards

[Scott Xe]

Hi Gert,

Thanks for your useful reply!  The EN 55032 : 2017/A11 : 2020 contains the
corrigendum only, no any technical changes.  Does AC have another condition
to qualify for?

Will arrange some time for visiting the CENELEC site.

Best regards,

Scott

On Wed, 24 Aug 2022 at 21:38, Gert Gremmen  wrote:

> Hi Scott,
>
> No only the :
>
> EN 55032 : 2017  is the Harmonised Standard (1 documnet)
> EN 55032 : 2017/A11 : 2020  is the (Harmonised) amendment only (1 dcoument)
>
> Both documents are needed. (did not check the OJ for you)
>
> EN 55032 : 2017+A11 : 2020  is both documents together.
>
> AC stands for Corrigendum, most used for plain error, typos ,wrong
> references etc.
>
> There is lots of info on the site of CENELEC on these subjects. Worth so
> spent an afternoon.
>
> Gert Gremmen
>
> On 24-8-2022 15:06, Scott Xe wrote:
> > EN 55032 : 2017/A11 : 2020
> >
> --
> Independent Expert on CE marking
> EMC Consultant
> Electrical Safety Consultant
>
> -
> 
> This message is from the IEEE Product Safety Engineering Society emc-pstc
> discussion list. To post a message to the list, send your e-mail to <
> emc-p...@ieee.org>
>
> All emc-pstc postings are archived and searchable on the web at:
> http://www.ieee-pses.org/emc-pstc.html
>
> Website:  http://www.ieee-pses.org/
> Instructions:  http://www.ieee-pses.org/list.html (including how to
> unsubscribe)
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[PSES] Harmonised standards

[Scott Xe]

Dear All,

I notice the reference number of the standard OJ is listed in OJ as below:-

EN 55032 : 2017,
EN 55032 : 2017/A11 : 2020

Does it mean that the EN 55032 : 2017 with or without A11 : 2020 is
acceptable as a harmonised standard?

Is /A11 : 2020 identical with +A11 : 2020?

EN 55032:2012/AC:2013

What does /AC mean?

Thanks and regards,

Scott

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Re: [PSES] Safety for e-scooters, e-bikes

[Scott Xe]

Dan,

It appears to me that Bosch's products are well designed and made in
general and agree to have high confidence in their products.

Rgds,

Scott


On Thu, 18 Aug 2022 at 21:30, Dan Roman <
0d75e04ed751-dmarc-requ...@listserv.ieee.org> wrote:

> Doug/Scott,
>
>
>
> My wife’s e-bike has a Bosch motor and battery and seems to be well made
> and certified so I am comfortable storing and charging it in my garage.
> Included a picture of the label with agency marks, sorry it is a little
> blurry.
>
>
>
> So I think there are definitely safety schemes available, but as with
> everything, quality may vary from vendor to vendor.  I would trust Bosch
> over a vendor I never heard of and the Bosch motor and battery certainly
> played a large role in picking which e-bike to purchase.
>
>
>
> Dan
>
>
>
>
>
> *From:* Scott Xe [mailto:scott...@gmail.com]
> *Sent:* Wednesday, August 17, 2022 10:54 AM
> *To:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Subject:* Re: [PSES] Safety for e-scooters, e-bikes
>
>
>
> Dear Doug,
>
>
>
> I learned that China prohibits carrying e-scooters and e-bikes to their
> houses and even entering the lifts of the building for storage/charging.
> Since the battery capacity is much bigger than the li-ion battery using in
> normal portable devices, the battery and the charger must comply with rigid
> safety requirements.  Do not recommend buying unknown brand products in
> this type of goods.
>
>
>
> Regards,
>
>
>
> Scott
>
>
>
>
>
> On Sat, 13 Aug 2022 at 05:27, Douglas E Powell  wrote:
>
> All,
>
>
>
> My Friday question is about storage/charging of e-scooters and e-bikes. It
> seems that these days more and more people are using these devices and fire
> safety is a growing concern. It seems my news feed has a new instance
> every few days.  Some of these cases are very tragic outcomes, in that the
> owner brings these devices just inside the door to their apartment for
> overnight charging.  Of course, if there is a lithium fire, it is rather
> violent and blocks the exit for the occupants.
>
>
>
> I am not very familiar with which safety standards are available in
> North America and Europe, and do they have requirements to address such
> concerns in the user documentation?  I do know that some building owners
> are taking matters into their own hands and requiring these devices be
> charged outdoors; which may have varying success in mitigating building
> fires.  In any case, many e-scooter owners are probably not very keen on
> leaving their property where it can be easily stolen.
>
>
>
> Thoughts?
>
>
>
> -Doug
>
>
>
> Laporte, Colorado USA
>
> LinkedIn <https://www.linkedin.com/in/coloradocomplianceguy/>
>
>
>
> (UTC -06:00) Mountain Time (US-MDT)
>
>
>
> -
> 
>
> This message is from the IEEE Product Safety Engineering Society emc-pstc
> discussion list. To post a message to the list, send your e-mail to 
> emc-p...@ieee.org
>
> All emc-pstc postings are archived and searchable on the web at:
> http://www.ieee-pses.org/emc-pstc.html
>
> Website: http://www.ieee-pses.org/
> Instructions: http://www.ieee-pses.org/list.html (including how to
> unsubscribe) <http://www.ieee-pses.org/list.html>
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>
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> --
>
> To unsubscribe from the EMC-PSTC list, click the following link:
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>
> -
> 
>
> This message is from the IEEE Product Safety Engineering Society emc-pstc
> discussion list. To post a message to the list, send your e-mail to <
> emc-p...@ieee.org>
>
> All emc-pstc postings are archived and searchable on the web at:
> http://www.ieee-pses.org/emc-pstc.html
>
> Website: http://www.ieee-pses.org/
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> unsubscribe) <http://www.ieee-pses.org/list.html>
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>
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> David Heald 
> --
>
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> -
> -

Re: [PSES] Safety for e-scooters, e-bikes

[Scott Xe]

Dear Doug,

Panasonic, ATL/CATL, BYD, Samsung, LG are good batteries for this type of
product.

Regards,

Scott

On Thu, 18 Aug 2022 at 22:37, Douglas E Powell  wrote:

> Thanks Dan,
>
> So I have to wonder what brand lithium battery Bosch is using.  And this
> is a great starting point for me to dig in a little.
>
> -Doug
>
>
> Douglas E Powell
> Laporte, Colorado USA
> doug...@gmail.com
> LinkedIn <https://www.linkedin.com/in/coloradocomplianceguy/>
>
> (UTC -06:00) Mountain Time (US-MDT)
>
>
> On Thu, Aug 18, 2022 at 7:30 AM Dan Roman <
> 0d75e04ed751-dmarc-requ...@listserv.ieee.org> wrote:
>
>> Doug/Scott,
>>
>>
>>
>> My wife’s e-bike has a Bosch motor and battery and seems to be well made
>> and certified so I am comfortable storing and charging it in my garage.
>> Included a picture of the label with agency marks, sorry it is a little
>> blurry.
>>
>>
>>
>> So I think there are definitely safety schemes available, but as with
>> everything, quality may vary from vendor to vendor.  I would trust Bosch
>> over a vendor I never heard of and the Bosch motor and battery certainly
>> played a large role in picking which e-bike to purchase.
>>
>>
>>
>> Dan
>>
>>
>>
>>
>>
>> *From:* Scott Xe [mailto:scott...@gmail.com]
>> *Sent:* Wednesday, August 17, 2022 10:54 AM
>> *To:* EMC-PSTC@LISTSERV.IEEE.ORG
>> *Subject:* Re: [PSES] Safety for e-scooters, e-bikes
>>
>>
>>
>> Dear Doug,
>>
>>
>>
>> I learned that China prohibits carrying e-scooters and e-bikes to their
>> houses and even entering the lifts of the building for storage/charging.
>> Since the battery capacity is much bigger than the li-ion battery using in
>> normal portable devices, the battery and the charger must comply with rigid
>> safety requirements.  Do not recommend buying unknown brand products in
>> this type of goods.
>>
>>
>>
>> Regards,
>>
>>
>>
>> Scott
>>
>>
>>
>>
>>
>> On Sat, 13 Aug 2022 at 05:27, Douglas E Powell  wrote:
>>
>> All,
>>
>>
>>
>> My Friday question is about storage/charging of e-scooters and e-bikes.
>> It seems that these days more and more people are using these devices and
>> fire safety is a growing concern. It seems my news feed has a new instance
>> every few days.  Some of these cases are very tragic outcomes, in that the
>> owner brings these devices just inside the door to their apartment for
>> overnight charging.  Of course, if there is a lithium fire, it is rather
>> violent and blocks the exit for the occupants.
>>
>>
>>
>> I am not very familiar with which safety standards are available in
>> North America and Europe, and do they have requirements to address such
>> concerns in the user documentation?  I do know that some building owners
>> are taking matters into their own hands and requiring these devices be
>> charged outdoors; which may have varying success in mitigating building
>> fires.  In any case, many e-scooter owners are probably not very keen on
>> leaving their property where it can be easily stolen.
>>
>>
>>
>> Thoughts?
>>
>>
>>
>> -Doug
>>
>>
>>
>> Laporte, Colorado USA
>>
>> LinkedIn <https://www.linkedin.com/in/coloradocomplianceguy/>
>>
>>
>>
>> (UTC -06:00) Mountain Time (US-MDT)
>>
>>
>>
>> -
>> 
>>
>> This message is from the IEEE Product Safety Engineering Society emc-pstc
>> discussion list. To post a message to the list, send your e-mail to 
>> emc-p...@ieee.org
>>
>> All emc-pstc postings are archived and searchable on the web at:
>> http://www.ieee-pses.org/emc-pstc.html
>>
>> Website: http://www.ieee-pses.org/
>> Instructions: http://www.ieee-pses.org/list.html (including how to
>> unsubscribe) <http://www.ieee-pses.org/list.html>
>> List rules: http://www.ieee-pses.org/listrules.html
>>
>> For help, send mail to the list administrators:
>> Mike Cantwell mcantw...@ieee.org
>>
>> For policy questions, send mail to:
>> Jim Bacher j.bac...@ieee.org
>> David Heald dhe...@gmail.com
>> --
>>
>> To unsubscribe from the EMC-PSTC list, click the following link:
>> https://listserv.ieee.org/cgi-bin/wa?SUBED1=EMC-PSTC=1
>>
>> -
>> --

Re: [PSES] Safety for e-scooters, e-bikes

[Scott Xe]

Dear Doug,

For EU market, below safety regulations/standards are applicable to your
products.

·   Toys Safety Directive 2009/48/EC

o   EN 14619 : 2019

o   EN 71

·   Machinery Directive 2006/42/EC

o   EN 12100-1 : 2010

·   General Product Safety Directive 2001/95/EC / Low Voltage Directive
2014/35/EU / Radio Equipment Directive 2014/53/EU

o   EN 17128 : 2020

o   EN 62133-2 : 2017 + A1 : 2021

o   EN 60529 : 1992 + A2 : 2013 Ingress protection

o   ISO 6742-1

o   ISO 14878

o   ISO 6742-2

o   EN 60335-1 : 2012 + A11 : 2014 + A13 : 2017 + A1 : 2019 + A2 : 2019 +
A14 : 2019 + A15 : 2021

o   EN 60335-2-114. Household and similar electrical appliances. Safety.
Part 2-114. Particular requirements for self-balancing personal transport
devices incorporating batteries containing alkaline or other non-acid
electrolytes

o   EN 60335-2-29 : 2004 + A2 : 2010 or EN 61558-1 & EN 61558-2-16

o   EN 15194 : 2017


Best regards,

Scott


On Thu, 18 Aug 2022 at 22:37, Douglas E Powell  wrote:

> Thanks Dan,
>
> So I have to wonder what brand lithium battery Bosch is using.  And this
> is a great starting point for me to dig in a little.
>
> -Doug
>
>
> Douglas E Powell
> Laporte, Colorado USA
> doug...@gmail.com
> LinkedIn <https://www.linkedin.com/in/coloradocomplianceguy/>
>
> (UTC -06:00) Mountain Time (US-MDT)
>
>
> On Thu, Aug 18, 2022 at 7:30 AM Dan Roman <
> 0d75e04ed751-dmarc-requ...@listserv.ieee.org> wrote:
>
>> Doug/Scott,
>>
>>
>>
>> My wife’s e-bike has a Bosch motor and battery and seems to be well made
>> and certified so I am comfortable storing and charging it in my garage.
>> Included a picture of the label with agency marks, sorry it is a little
>> blurry.
>>
>>
>>
>> So I think there are definitely safety schemes available, but as with
>> everything, quality may vary from vendor to vendor.  I would trust Bosch
>> over a vendor I never heard of and the Bosch motor and battery certainly
>> played a large role in picking which e-bike to purchase.
>>
>>
>>
>> Dan
>>
>>
>>
>>
>>
>> *From:* Scott Xe [mailto:scott...@gmail.com]
>> *Sent:* Wednesday, August 17, 2022 10:54 AM
>> *To:* EMC-PSTC@LISTSERV.IEEE.ORG
>> *Subject:* Re: [PSES] Safety for e-scooters, e-bikes
>>
>>
>>
>> Dear Doug,
>>
>>
>>
>> I learned that China prohibits carrying e-scooters and e-bikes to their
>> houses and even entering the lifts of the building for storage/charging.
>> Since the battery capacity is much bigger than the li-ion battery using in
>> normal portable devices, the battery and the charger must comply with rigid
>> safety requirements.  Do not recommend buying unknown brand products in
>> this type of goods.
>>
>>
>>
>> Regards,
>>
>>
>>
>> Scott
>>
>>
>>
>>
>>
>> On Sat, 13 Aug 2022 at 05:27, Douglas E Powell  wrote:
>>
>> All,
>>
>>
>>
>> My Friday question is about storage/charging of e-scooters and e-bikes.
>> It seems that these days more and more people are using these devices and
>> fire safety is a growing concern. It seems my news feed has a new instance
>> every few days.  Some of these cases are very tragic outcomes, in that the
>> owner brings these devices just inside the door to their apartment for
>> overnight charging.  Of course, if there is a lithium fire, it is rather
>> violent and blocks the exit for the occupants.
>>
>>
>>
>> I am not very familiar with which safety standards are available in
>> North America and Europe, and do they have requirements to address such
>> concerns in the user documentation?  I do know that some building owners
>> are taking matters into their own hands and requiring these devices be
>> charged outdoors; which may have varying success in mitigating building
>> fires.  In any case, many e-scooter owners are probably not very keen on
>> leaving their property where it can be easily stolen.
>>
>>
>>
>> Thoughts?
>>
>>
>>
>> -Doug
>>
>>
>>
>> Laporte, Colorado USA
>>
>> LinkedIn <https://www.linkedin.com/in/coloradocomplianceguy/>
>>
>>
>>
>> (UTC -06:00) Mountain Time (US-MDT)
>>
>>
>>
>> -
>> 
>>
>> This message is from the IEEE Product Safety Engineering Society emc-pstc
>> discussion list. To post a message to the list, send your e-mail to 
>> emc-p

Re: [PSES] Safety for e-scooters, e-bikes

[Scott Xe]

Dear Doug,

I learned that China prohibits carrying e-scooters and e-bikes to their
houses and even entering the lifts of the building for storage/charging.
Since the battery capacity is much bigger than the li-ion battery using in
normal portable devices, the battery and the charger must comply with rigid
safety requirements.  Do not recommend buying unknown brand products in
this type of goods.

Regards,

Scott


On Sat, 13 Aug 2022 at 05:27, Douglas E Powell  wrote:

> All,
>
> My Friday question is about storage/charging of e-scooters and e-bikes. It
> seems that these days more and more people are using these devices and fire
> safety is a growing concern. It seems my news feed has a new instance
> every few days.  Some of these cases are very tragic outcomes, in that the
> owner brings these devices just inside the door to their apartment for
> overnight charging.  Of course, if there is a lithium fire, it is rather
> violent and blocks the exit for the occupants.
>
> I am not very familiar with which safety standards are available in
> North America and Europe, and do they have requirements to address such
> concerns in the user documentation?  I do know that some building owners
> are taking matters into their own hands and requiring these devices be
> charged outdoors; which may have varying success in mitigating building
> fires.  In any case, many e-scooter owners are probably not very keen on
> leaving their property where it can be easily stolen.
>
> Thoughts?
>
> -Doug
>
> Laporte, Colorado USA
> LinkedIn 
>
> (UTC -06:00) Mountain Time (US-MDT)
>
> -
> 
>
> This message is from the IEEE Product Safety Engineering Society emc-pstc
> discussion list. To post a message to the list, send your e-mail to 
> emc-p...@ieee.org
>
> All emc-pstc postings are archived and searchable on the web at:
> http://www.ieee-pses.org/emc-pstc.html
>
> Website: http://www.ieee-pses.org/
> Instructions: http://www.ieee-pses.org/list.html (including how to
> unsubscribe) 
> List rules: http://www.ieee-pses.org/listrules.html
>
> For help, send mail to the list administrators:
> Mike Cantwell mcantw...@ieee.org
>
> For policy questions, send mail to:
> Jim Bacher j.bac...@ieee.org
> David Heald dhe...@gmail.com
> --
>
> To unsubscribe from the EMC-PSTC list, click the following link:
> https://listserv.ieee.org/cgi-bin/wa?SUBED1=EMC-PSTC=1
>

-

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discussion list. To post a message to the list, send your e-mail to 


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Re: [PSES] EN amendments of EN standard vs BS EN emendments of BS EN standard

[Scott Xe]

Dear Bernd,

Yes, you are correct that the A11 : 2020 modifies the Annex ZZ reference to
the latest Directive 2014/30/EU from old Directive 2004/108/EC.  A11 is on
OJ but A1 is not yet.  I have checked EN 55032 : 2015/A1 : 2020 and it does
not include A11 contents.  For BS EN 55032 : 2015 + A1 : 2020, in the
publication preview, it does include A11.  If the product was tested and
passed with BS EN 55032 : 2015 + A1 : 2020, it complies with both A11 and
A1 amendments.

If the test house uses EN amendments, their test report should state A11
and A1 as they have individual requirements.  Sometimes the products may
need to be upgraded for A1 compliance.  Thus they may be conducted
separately.

Regards,

Scott

On Mon, 25 Jul 2022 at 14:53, Dürrer Bernd  wrote:

> Hi Scott,
>
>
>
> the content of EN amendment A11 is the “Modification to Annex ZZ,
> "Coverage of Essential Requirements of EU Directives"”, while EN amendment
> A1 is the adoption of CISPR amendment A1 without any modifications. I
> presume that the statement in BS EN 55032:2015 is related to Brexit, as the
> UK no longer recognises EU Directives, but only UK regulations (cf. 
> relationship-between-eu-and-uk-regulation_table.pdf
> (bsigroup.com)
> <https://www.bsigroup.com/globalassets/documents/about-bsi/nsb/national-and-european-policy-team/relationship-between-eu-and-uk-regulation_table.pdf>).
> Please check Standards and EU Exit | BSI (bsigroup.com)
> <https://www.bsigroup.com/en-GB/about-bsi/uk-national-standards-body/standards-and-eu-exit/>
>  for
> information on this topic published by the British Standards Institution.
> At the end of this page you will find a contact e-mail to which you may
> submit your question on the adoption of EN amendments by BSI.
>
>
>
> Kind regards,
>
>
>
> Bernd
>
>
>
> *Von:* Scott Xe 
> *Gesendet:* Samstag, 23. Juli 2022 15:30
> *An:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Betreff:* [PSES] EN amendments of EN standard vs BS EN emendments of BS
> EN standard
>
>
>
> Recently we had a discussion of differences between these two types of
> amendments.  The amendments of an EN standard are independent whereas the
> amendments of BS EN standard are accumulated.  The latest amendment of BS
> EN standard supersedes the previous ones.
>
>
>
> The discussion was based on a EMC standard, EN 55032 : 2015 + A11 : 2020 +
> A1 : 2020.  A11 and A1 amendments are independent.  BS EN 55022 : 2015/A1
> supersedes BS EN 55032:2015+A11:2020 but this statement is not in EN A1
> amendment.
>
>
>
> Are they the correct interpretation?  Originally we believe EN amendments
> are more or less the same as BS EN amendments.
>
>
>
> Thanks and regards,
>
>
>
> Scott
>
> -
> 
>
> This message is from the IEEE Product Safety Engineering Society emc-pstc
> discussion list. To post a message to the list, send your e-mail to <
> emc-p...@ieee.org>
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>

[PSES] EN amendments of EN standard vs BS EN emendments of BS EN standard

[Scott Xe]

Recently we had a discussion of differences between these two types of
amendments.  The amendments of an EN standard are independent whereas the
amendments of BS EN standard are accumulated.  The latest amendment of BS
EN standard supersedes the previous ones.

The discussion was based on a EMC standard, EN 55032 : 2015 + A11 : 2020 +
A1 : 2020.  A11 and A1 amendments are independent.  BS EN 55022 : 2015/A1
supersedes BS EN 55032:2015+A11:2020 but this statement is not in EN A1
amendment.

Are they the correct interpretation?  Originally we believe EN amendments
are more or less the same as BS EN amendments.

Thanks and regards,

Scott

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Re: [PSES] UKCA

[Scott Xe]

It said UK Gov will issue a divergency tracker from EU compliance for the
manufacturers to adopt easily on products to the UK market.  For example,
recently EU passed the new requirement of a USB-C port for battery chargers
and mobile units to reduce the electronic waste.  UK claims that they may
not adopt this requirement.  We need to keep our eyes on it closely.  If
the tracker becomes available, it will help the manufacturers a lot.

Regards,

Scott

On Tue, 28 Jun 2022 at 14:11, Amund Westin  wrote:

> What is your experience:
>
>- Will a UKCA Notified Body normally approve the use of old test
>results (approx. 10 years old EMC report) under a conformity assessment
>today? We are preparing for some EMC testing, but wanted to re-use some
>results, to keep down the scope as much as possible.
>
> The product is unmodified since last test, even some uncritical components
> (passive) have been changed during the years. I realize that re-use of 10
> years old test results sounds on the edge of what is reasonable, but I’m
> mostly interested in the UKCA procedure regarding use of past results, no
> matter how old they are.
>
> Thanks!
>
> BR
> Amund
>
>
>
>
> -
> 
>
> This message is from the IEEE Product Safety Engineering Society emc-pstc
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[PSES] VDE 0620-1 2021-02 General requirements on fixed socket-outlets

[Scott Xe]

We have received a GS certification that states an applicable standard, VDE
0620-1 : 2016 + A1 : 2017 that is invalid and replaced by 2021 version.  Is
there any transitional period from 2016 version to 2021 version?  Your
guidance is appreciated!

Thanks and regards,

Scott

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Re: [PSES] EN 55032-2015+A1-2020/EN 55032-2015+A11-2020

[Scott Xe]

Dear David,

Last week, I encountered a similar issue and would like to share with you.
We received a compliance report using EN 55032 : 2015/A1 : 2020, no A11 :
2020 from our supplier.  The test house applied the latest amendment of A1
only for their customer.  Considering that the product was updated from EN
55032 : 2015 and A11 just added Annex ZZ updating EN 55032 : 2015 in
complying with the latest EMC Directive 2014/30/EU instead of previous
Directive 2004/108/EC - No technical changes, we suggested the supplier to
give us the previous compliance report of EN 55032 : 2015 and A11
statement.  The A1 : 2020 has not been harmonised and listed in OJEU.  We
can wait for corresponding action until further development in OJEU.

Best regards,

Scott

On Wed, 27 Oct 2021 at 16:40, David Shidlovsky  wrote:

> Hello
>
> I have seen EN 55032-2015 listed with either A1-2020 or A11-2020.
>
> Is there any difference between them or is it just a typo?
>
>
>
> *Best Regards,*
>
> *David Shidlowsky*
>
> *Technical Reviewer*
>
> *Address 1 Bat-Sheva St. POB **6117**, LOD**7120101   **Israel  *
>
> *Tel: 972-8-9186100 Ext. 213 Direct: 972-8-9186113   Fax: 972-8-9153101*
>
> *Mail: *dav...@itlglobal.org
>
> *Web **www.itlglobal.org* 
>
>
>
> *Waze* *ITL*: https://waze.com/ul/hsv8vccn2j
>
> 
> *https://www.linkedin.com/company/itl-israel-testing-laboratories**/*
> 
>
>
>
>
>
>
> -
> 
>
> This message is from the IEEE Product Safety Engineering Society emc-pstc
> discussion list. To post a message to the list, send your e-mail to 
> emc-p...@ieee.org
>
> All emc-pstc postings are archived and searchable on the web at:
> http://www.ieee-pses.org/emc-pstc.html
>
> Attachments are not permitted but the IEEE PSES Online Communities site at
> http://product-compliance.oc.ieee.org/ can be used for graphics (in
> well-used formats), large files, etc.
>
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[PSES] DoC for Republic of Ireland and Republic of Cyprus markets

[Scott Xe]

Both countries are using BS 1363 plugs and sockets.  We have a cord
extension set for the UK market and complies with Plugs and Sockets etc.
(Safety) Regulations 1994 (SI 1994/1768).  Do both Republic of Ireland and
Republic of Cyprus recognise the UK compliance as EU LVD compliance in EU
DoC?

Thanks and regards,

Scott

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Re: [PSES] AW: [PSES] EN Standard amendments

[Scott Xe]

Thanks Charlie!

Yes, you are right that as a client the test lab follows the instructions
of required testing.  The product compliance engineer is ideal to have
testing experience in order to understand the test results.

Regards,

Scott


On Thu, 14 Apr 2022 at 03:42, Charlie Blackham 
wrote:

> Scott
>
>
>
> The A11 amendments to EN 55032 and 55035 do not make any technical changes
> to the standard, so a test report without them can be used to support a DoC
> that lists them – you should just add a covering comment in your Technical
> File
>
>
>
> As to your point about which version a lab tests against – they should
> test against the version that you ask them to – it’s your responsibility as
> the manufacturer which standard you apply, not the test labs – their
> responsibility is to perform the required tests correctly
>
>
>
> Best regards
>
> Charlie
>
>
>
> *Charlie Blackham*
>
> *Sulis Consultants Ltd*
>
> *Tel: +44 (0)7946 624317*
>
> *Web: https://sulisconsultants.com/ <https://sulisconsultants.com/> *
>
> Registered in England and Wales, number 05466247
>
>
>
> *From:* Scott Xe 
> *Sent:* 13 April 2022 16:16
> *To:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Subject:* Re: [PSES] AW: [PSES] EN Standard amendments
>
>
>
> Hi Bernd,
>
>
>
> Many thanks for your comments.  Can we consider IEC amendment as non-EN
> amendment and it should be applied by non-EU countries.
>
>
>
> I have a recent case on a conformity test report that adopts A1 amendment
> only.  However in OJEU it states A11.  There is a risk for the market
> surveillance to challenge the missing A11 amendment.  I am unsure if both
> A1 and A11 refer to the same topic or different one.
>
>
>
> In the similar case, the public test house will do the conformity test
> using the latest version of standard.  If OJEU does not or has not adopted
> the latest version of a standard as harmonised standard, it may bring us
> unnecessary frustration about invalid standard applied when we deal with
> market surveillance.  Of course, we can adopt whatever standards apart from
> harmonised standards but need to convene the market surveillance in
> agreement.
>
>
>
> Best regards,
>
>
>
> Scott
>
>
>
>
>
> On Wed, 13 Apr 2022 at 19:17, Dürrer Bernd  wrote:
>
> Hi Scott,
>
>
>
> all amendments published by CENELEC are applicable. You may check on
> published amendments using the standards search provided by CENELEC (for
> EN 55032 https://standards.cencenelec.eu/dyn/www/f?p=205:105:0:).
> Typically, an amendment A11 is published by CENELEC to establish the
> correspondence between the standard and the essential requirements of the
> applicable EU directive. This may also include modifications to the
> standard (for example in EN 55032/A11: “With respect to Clause 11
> (Measurement uncertainty), the following shall not be applied, if Clause 5
> (Requirements) is applied for the purposes of the presumption of
> conformity: 'Refer to CISPR TR 16-4-3 for guidance on the applicability of
> the limits to a series production MME'.”). Such an amendment A11 is now a
> legal prerequisite of having the standard listed in the Official Journal of
> the EU. The OJEU may not list all amendments (for EN 55032, the amendment
> A1 is not listed, cf. https://ec.europa.eu/docsroom/documents/45365).
> Nevertheless, you are free to reference standards in your Declaration of
> Conformity that are not listed in the OJEU (even non-EN standards), and if
> your DoC resp. your test report is based on an unlisted standard or
> amendment (e.g. EN 55032/A1), I recommend to reference it in the DoC.
>
>
>
> Kind regards,
>
>
>
> Bernd
>
>
>
> *Von:* Scott Xe 
> *Gesendet:* Mittwoch, 13. April 2022 12:53
> *An:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Betreff:* [PSES] EN Standard amendments
>
>
>
> EN standards have two types of amendment: A1 - A9 and/or A11 - A19.  As
> far as I know, A1 - A9 come from IEC/CISPR standard whereas A11 - A19 from
> CENELEC EN standard.  For products to EU markets, does the product comply
> with A11 - A19 only?
>
>
>
> For example, EN 55032 : 2015 has both A1 : 2020 and + A11 : 2020.  Is A1 :
> 2020 only applied for markets outside the EU?
>
>
>
> Thanks and regards,
>
>
>
> Scott
>
> -
> 
>
> This message is from the IEEE Product Safety Engineering Society emc-pstc
> discussion list. To post a message to the list, send your e-mail to <
> emc-p...@ieee.org>
>
> All emc-pstc postings are archived and searchable on the web at:
> http://www.ieee-pses.org/emc-pst

Re: [PSES] AW: [PSES] EN Standard amendments

[Scott Xe]

Hi Bernd,

Many thanks for your comments.  Can we consider IEC amendment as non-EN
amendment and it should be applied by non-EU countries.

I have a recent case on a conformity test report that adopts A1 amendment
only.  However in OJEU it states A11.  There is a risk for the market
surveillance to challenge the missing A11 amendment.  I am unsure if both
A1 and A11 refer to the same topic or different one.

In the similar case, the public test house will do the conformity test
using the latest version of standard.  If OJEU does not or has not adopted
the latest version of a standard as harmonised standard, it may bring us
unnecessary frustration about invalid standard applied when we deal with
market surveillance.  Of course, we can adopt whatever standards apart from
harmonised standards but need to convene the market surveillance in
agreement.

Best regards,

Scott


On Wed, 13 Apr 2022 at 19:17, Dürrer Bernd  wrote:

> Hi Scott,
>
>
>
> all amendments published by CENELEC are applicable. You may check on
> published amendments using the standards search provided by CENELEC (for
> EN 55032 https://standards.cencenelec.eu/dyn/www/f?p=205:105:0:).
> Typically, an amendment A11 is published by CENELEC to establish the
> correspondence between the standard and the essential requirements of the
> applicable EU directive. This may also include modifications to the
> standard (for example in EN 55032/A11: “With respect to Clause 11
> (Measurement uncertainty), the following shall not be applied, if Clause 5
> (Requirements) is applied for the purposes of the presumption of
> conformity: 'Refer to CISPR TR 16-4-3 for guidance on the applicability of
> the limits to a series production MME'.”). Such an amendment A11 is now a
> legal prerequisite of having the standard listed in the Official Journal of
> the EU. The OJEU may not list all amendments (for EN 55032, the amendment
> A1 is not listed, cf. https://ec.europa.eu/docsroom/documents/45365).
> Nevertheless, you are free to reference standards in your Declaration of
> Conformity that are not listed in the OJEU (even non-EN standards), and if
> your DoC resp. your test report is based on an unlisted standard or
> amendment (e.g. EN 55032/A1), I recommend to reference it in the DoC.
>
>
>
> Kind regards,
>
>
>
> Bernd
>
>
>
> *Von:* Scott Xe 
> *Gesendet:* Mittwoch, 13. April 2022 12:53
> *An:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Betreff:* [PSES] EN Standard amendments
>
>
>
> EN standards have two types of amendment: A1 - A9 and/or A11 - A19.  As
> far as I know, A1 - A9 come from IEC/CISPR standard whereas A11 - A19 from
> CENELEC EN standard.  For products to EU markets, does the product comply
> with A11 - A19 only?
>
>
>
> For example, EN 55032 : 2015 has both A1 : 2020 and + A11 : 2020.  Is A1 :
> 2020 only applied for markets outside the EU?
>
>
>
> Thanks and regards,
>
>
>
> Scott
>
> -
> 
>
> This message is from the IEEE Product Safety Engineering Society emc-pstc
> discussion list. To post a message to the list, send your e-mail to <
> emc-p...@ieee.org>
>
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[PSES] EN Standard amendments

[Scott Xe]

EN standards have two types of amendment: A1 - A9 and/or A11 - A19.  As far
as I know, A1 - A9 come from IEC/CISPR standard whereas A11 - A19 from
CENELEC EN standard.  For products to EU markets, does the product comply
with A11 - A19 only?

For example, EN 55032 : 2015 has both A1 : 2020 and + A11 : 2020.  Is A1 :
2020 only applied for markets outside the EU?

Thanks and regards,

Scott

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Re: [PSES] EN 62368-1 : 2020 Ed 3

[scott . xe]

Hi Charlie,

 

It is pity.  The risk assessment may have variants and inconsistence amongst 
test engineers and make the compliance more difficult.

 

Regards,

 

Scott

 

 

 

From: Charlie Blackham  
Sent: Friday, 11 February 2022 6:10 pm
To: scott...@gmail.com; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] EN 62368-1 : 2020 Ed 3

 

Scott

 

There’s no better system on the way – we’re stuck with the current one!

 

As always, Harmonised Standards provide a “presumption of conformity”, but 
manufacturers must also document a risk assessment and determine whether the 
applied standard covers all foreseeable risks, and if not, what other measures 
have been taken as per LVD Annex III

 

Best regards

Charlie

 

Charlie Blackham

Sulis Consultants Ltd

Tel: +44 (0)7946 624317

Web: https://sulisconsultants.com/ 

Registered in England and Wales, number 05466247

 

From: scott...@gmail.com   mailto:scott...@gmail.com> > 
Sent: 11 February 2022 01:34
To: Charlie Blackham mailto:char...@sulisconsultants.com> >; EMC-PSTC@LISTSERV.IEEE.ORG 
 
Subject: RE: [PSES] EN 62368-1 : 2020 Ed 3

 

Hi Charlie,

 

Did you mean the current system is no longer to work anymore or is any better 
system on the way?  How do the market surveillances conduct their sampling 
checks on the market?  Just discover 6 Jan 2023 of is the DOW of last version 
on the new standard.  Is it the correct way to follow if Ed 3 will not be 
listed in OJ?

 

Rgds,

 

Scott

 

 

From: Charlie Blackham mailto:char...@sulisconsultants.com> > 
Sent: Thursday, 10 February 2022 10:04 pm
To: scott...@gmail.com  ; EMC-PSTC@LISTSERV.IEEE.ORG 
 
Subject: RE: [PSES] EN 62368-1 : 2020 Ed 3

 

Scott

 

It’s never going to be listed in the OJ

 

The EU Commission have rejected for multiple clauses not giving legal 
presumption of conformity

 

(As an aside, the current version would be rejected if reviewed against the 
current criteria as well)

 

Best regards

Charlie

 

Charlie Blackham

Sulis Consultants Ltd

Tel: +44 (0)7946 624317

Web: https://sulisconsultants.com/ 

Registered in England and Wales, number 05466247

 

From: scott...@gmail.com   mailto:scott...@gmail.com> > 
Sent: 10 February 2022 13:13
To: EMC-PSTC@LISTSERV.IEEE.ORG  
Subject: [PSES] EN 62368-1 : 2020 Ed 3

 

I learned this standard will become in force on 6 Jan 2023.  However I could 
not find it in OJ as a harmonised standard replacing the Ed 2.  It is difficult 
in encouraging the suppliers to use this new standard without official 
confirmation.  Is anyone aware of when it will be available in OJ?

 

Thanks and regards,

 

Scott

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Re: [PSES] EN 62368-1 : 2020 Ed 3

[scott . xe]

Hi Charlie,

 

Did you mean the current system is no longer to work anymore or is any better 
system on the way?  How do the market surveillances conduct their sampling 
checks on the market?  Just discover 6 Jan 2023 of is the DOW of last version 
on the new standard.  Is it the correct way to follow if Ed 3 will not be 
listed in OJ?

 

Rgds,

 

Scott

 

 

From: Charlie Blackham  
Sent: Thursday, 10 February 2022 10:04 pm
To: scott...@gmail.com; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] EN 62368-1 : 2020 Ed 3

 

Scott

 

It’s never going to be listed in the OJ

 

The EU Commission have rejected for multiple clauses not giving legal 
presumption of conformity

 

(As an aside, the current version would be rejected if reviewed against the 
current criteria as well)

 

Best regards

Charlie

 

Charlie Blackham

Sulis Consultants Ltd

Tel: +44 (0)7946 624317

Web: https://sulisconsultants.com/ 

Registered in England and Wales, number 05466247

 

From: scott...@gmail.com   mailto:scott...@gmail.com> > 
Sent: 10 February 2022 13:13
To: EMC-PSTC@LISTSERV.IEEE.ORG  
Subject: [PSES] EN 62368-1 : 2020 Ed 3

 

I learned this standard will become in force on 6 Jan 2023.  However I could 
not find it in OJ as a harmonised standard replacing the Ed 2.  It is difficult 
in encouraging the suppliers to use this new standard without official 
confirmation.  Is anyone aware of when it will be available in OJ?

 

Thanks and regards,

 

Scott

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[PSES] EN 62368-1 : 2020 Ed 3

[scott . xe]

I learned this standard will become in force on 6 Jan 2023.  However I could 
not find it in OJ as a harmonised standard replacing the Ed 2.  It is difficult 
in encouraging the suppliers to use this new standard without official 
confirmation.  Is anyone aware of when it will be available in OJ?

 

Thanks and regards,

 

Scott


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Re: [PSES] CE marked products

[Scott Xe]

Fully agree on such design.  However the bag of adapters should be optional
so the user will obtain it when needed to avoid e-waste.

Rgds,

Scott

On Wed, 26 Jan 2022 at 23:07, Bill Owsley  wrote:

> We handled the power cords as separate items with their own approvals.
> And depending on the country the product was being shipped to, the correct
> power cord was added to shipment.
> If a citizen is moving a product from country to country, it is their
> problem to get the correct power cord for country receptacles.
> The flexibility of detachable power cords allows for the mixing and
> matching.
> If a product design is such that a detachable power cord is not available,
> well, get creative with a bag of adapters.
> If a product has the power cord wired into the device, it becomes a
> country specific device, or it gets a bag of adapters to fit into whatever
> country it is in.
>
>
> On Wednesday, January 26, 2022, 09:38:45 AM EST, scott...@gmail.com <
> scott...@gmail.com> wrote:
>
>
> In general understanding, products bearing CE Mark are free movement in
> the EU. I doubt how can they do it.  For example, a Euro plug is fitted in
> the product.  How can it operate in Ireland where UK plug is common?  Do
> the products mark the CE Mark incorrectly or must the products comply with
> all national deviations in the LVD standard (some EPSs do supply different
> plugs but costly & not common on products)?  Did I miss something in the
> requirements to look after this scenario?  Appreciate the guidance to read
> the requirements correctly!
>
>
>
> Thanks and regards,
>
>
>
> Scott
> -
> 
>
> This message is from the IEEE Product Safety Engineering Society emc-pstc
> discussion list. To post a message to the list, send your e-mail to <
> emc-p...@ieee.org>
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>
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> well-used formats), large files, etc.
>
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>
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Re: [PSES] [PSES] CE marked products

[Scott Xe]

That is to say the manufacturers are liable to supply the right plug with
the product for the market to be placed, not necessary for all 27 markets.
If the user moves the product to another country, the user is liable to
adopt a correct converter.

Thanks and regards,

Scott

On Wed, 26 Jan 2022 at 22:47,  wrote:

> Scott
>
>
>
> In the UK (don’t know about Eire) the law (UK Plug & Socket Regs 1994
> https://www.legislation.gov.uk/uksi/1994/1768/made) Clause 9 require that
> an appliance with a non-UK plug be supplied with a suitable “conversion
> plug” that does meet UK requirements and will fit a standard UK 13A socket.
> Suitable “conversion plugs” are widely available in the UK.
>
>
>
> John E Allen
>
> W. London, UK
>
> *From:* scott...@gmail.com 
> *Sent:* 26 January 2022 14:39
> *To:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Subject:*  [PSES] CE marked products
>
>
>
> In general understanding, products bearing CE Mark are free movement in
> the EU. I doubt how can they do it.  For example, a Euro plug is fitted in
> the product.  How can it operate in Ireland where UK plug is common?  Do
> the products mark the CE Mark incorrectly or must the products comply with
> all national deviations in the LVD standard (some EPSs do supply different
> plugs but costly & not common on products)?  Did I miss something in the
> requirements to look after this scenario?  Appreciate the guidance to read
> the requirements correctly!
>
>
>
> Thanks and regards,
>
>
>
> Scott
>
> -
> 
>
> This message is from the IEEE Product Safety Engineering Society emc-pstc
> discussion list. To post a message to the list, send your e-mail to <
> emc-p...@ieee.org>
>
> All emc-pstc postings are archived and searchable on the web at:
> http://www.ieee-pses.org/emc-pstc.html
>
> Attachments are not permitted but the IEEE PSES Online Communities site at
> http://product-compliance.oc.ieee.org/ can be used for graphics (in
> well-used formats), large files, etc.
>
> Website: http://www.ieee-pses.org/
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> unsubscribe) 
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>
> For help, send mail to the list administrators:
> Scott Douglas 
> Mike Cantwell 
>
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> Jim Bacher 
> David Heald 
>

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[PSES] CE marked products

[scott . xe]

In general understanding, products bearing CE Mark are free movement in the EU. 
I doubt how can they do it.  For example, a Euro plug is fitted in the product. 
 How can it operate in Ireland where UK plug is common?  Do the products mark 
the CE Mark incorrectly or must the products comply with all national 
deviations in the LVD standard (some EPSs do supply different plugs but costly 
& not common on products)?  Did I miss something in the requirements to look 
after this scenario?  Appreciate the guidance to read the requirements 
correctly!

 

Thanks and regards,

 

Scott


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Re: [PSES] Notice about LVD compliance in a DoC for machinery?

[scott . xe]

Regarding your second statement, did you mean EMF that is part of LVD?  EMC and 
LVD are two independent directives.

Regards,

Scott 

-Original Message-
From: Paasche, Dieter  
Sent: Tuesday, 25 January 2022 3:45 am
To: 'scott...@gmail.com' ; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] Notice about LVD compliance in a DoC for machinery?

I think that the EMC directive is not specifically mentioned in the MD as it is 
in RED, unless you consider it a radiation (annex 1 section "1.5.10. 
Radiation"). However EMC compliance is required in the electrical safety 
standard for machinery EN60204-1. 

Sincerely, 





Dieter Paasche
Senior Product Developer
Electrical / EMC Compliance
dieter.paas...@christedigital.com
Work: (519) 744-8005 Ext. 7211
www.christiedigital.com




809 Wellington St. N.
Kitchener, Ontario
N2G 4Y7 Canada




This e-mail message (including attachments, if any) is confidential.  Any 
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-Original Message-
From: scott...@gmail.com 
Sent: Saturday, January 22, 2022 9:50 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Notice about LVD compliance in a DoC for machinery?

CAUTION:This email originated from outside of the organization. Do not click 
links or open attachments unless you recognize the sender and know the content 
is safe.


The MD Directive is quite similar with RED which includes both LVD and EMC.  No 
one quotes LVD and EMC separated from RED.  We can put LVD compliance and 
applicable standards under MD Directive compliance.  Does MD Directive include 
EMC?  If not, EMC if required should be stated in the DoC outside the MD 
compliance.

Regards,

Scott

-Original Message-
From: Oliver Betz 
Sent: Wednesday, 19 January 2022 4:56 pm
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Notice about LVD compliance in a DoC for machinery?

Dürrer Bernd wrote:

(Annex II of the Machinery Directive point 4)

> "a sentence expressly declaring that the machinery fulfils all the 
> relevant provisions of this Directive and where appropriate, a similar 
> sentence declaring the conformity with other Directives
Correct.

In my current understanding, the phrase "shall not refer to the LVD but to the 
MD" means that the DoC has to be issued under the rules of the MD, but it does 
not mean that LVD is a "Directive Which Cannot Be Named"
in a machinery DoC.

Oliver

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Re: [PSES] Notice about LVD compliance in a DoC for machinery?

[scott . xe]

The MD Directive is quite similar with RED which includes both LVD and EMC.  No 
one quotes LVD and EMC separated from RED.  We can put LVD compliance and 
applicable standards under MD Directive compliance.  Does MD Directive include 
EMC?  If not, EMC if required should be stated in the DoC outside the MD 
compliance.

Regards,

Scott

-Original Message-
From: Oliver Betz  
Sent: Wednesday, 19 January 2022 4:56 pm
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Notice about LVD compliance in a DoC for machinery?

Dürrer Bernd wrote:

(Annex II of the Machinery Directive point 4)

> "a sentence expressly declaring that the machinery fulfils all the 
> relevant provisions of this Directive and where appropriate, a similar 
> sentence declaring the conformity with other Directives
Correct.

In my current understanding, the phrase "shall not refer to the LVD but to the 
MD" means that the DoC has to be issued under the rules of the MD, but it does 
not mean that LVD is a "Directive Which Cannot Be Named"
in a machinery DoC.

Oliver

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Re: [PSES] [EXTERNAL] [PSES] Touch temperature limits for accessible parts

[Scott Xe]

Dear Ted,

Appreciate your view & advice!

The charger with a detachable cable is normally left in the
cigarette socket from day one.  The user will use it when in the car or
battery low of mobile phone (common object to be charged).  As per charging
protocol, the most likely full load would happen when the battery is at
very low level.  Then the charging current will decrease gradually.  The
chance of full load would be in a short period of time like your driving
speed example.  Probably I need to assess the risk of burn and
possibilities of reducing the max temp.

Regards,

Scott

On Fri, 3 Sept 2021 at 00:36, Ted Eckert  wrote:

> Hello Scott,
>
>
>
> IEC 62368-1 clause 3.3.7.4 defines “normal operating condition” as the
> “mode of operation that represents as closely as possible the range of
> normal use that can be reasonably expected”. It specifies the range of
> possible uses, not the “typical” use. Note 1 for the clause makes it clear
> that the most unfavorable default conditions must be considered for normal
> use.
>
>
>
> If your charger is permanently connected to the device that it is
> charging, is it possible to load the device such that it continuously draws
> the maximum power from the charger? If the charger has a connector,
> allowing different loads to be connected, could the user charge a series of
> devices, one after the other, keeping the charger at maximum power for an
> extended time? “Normal” does not mean “likely” or “common”. “Normal” is
> what is allowed and foreseeable.
>
>
>
> In the United States, a number of mountain and southwestern states have
> freeway speed limits up to 80 miles per hour. The vast majority of cars in
> the United States will never travel at 80 mph for extended periods. If you
> did a survey, I would expect you to find that, on average, the typical
> American car spends less than 0.1% of the time at 80 mph. However,
> travelling continuously at that speed is allowed and possible, and a small
> subset of drivers will drive at that speed regularly. It’s neither typical
> nor common, but it is “normal” and must be considered a normal condition.
>
>
>
> Ted Eckert
>
> The opinions expressed are my own and do not necessarily reflect those of
> my employer.
>
>
>
> *From:* Scott Xe 
> *Sent:* Thursday, September 2, 2021 8:02 AM
> *To:* Ted Eckert 
> *Cc:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Subject:* Re: [EXTERNAL] [PSES] Touch temperature limits for accessible
> parts
>
>
>
> Dear Ted,
>
>
>
> Many thanks for your good considerations!  I need to re-assess this issue
> inclusive of those conditions.  I have one conflicted point about the touch
> temperature of 80 degC which is at full load.  As you may know it, the full
> load may happen at the initial charging and the charging current will
> gradually decrease.  In general, it may not be so hot in normal
> conditions.  What is your view on this?
>
>
>
> Kindest regards,
>
>
>
> Scott
>
>
>
> On Thu, 2 Sept 2021 at 21:43, Ted Eckert  wrote:
>
> Hello Scott,
>
>
>
> Touch temperatures are measured at an ambient of 25 C. However, there are
> a number of additional considerations.
>
>- What are normal operating conditions? Is it true that the user would
>never touch the charger while it is in operation? There is no chance that
>they would try to disconnected it from the car’s socket while it is at
>maximum temperature?
>- If the user could disconnect it, how long do they need to hold it to
>pull it out of the car’s socket? Consider all users. For example, somebody
>with arthritis and a poor grip might need more time to disconnect the
>charger.
>- Think about how TS2 limits apply to touch temperatures. What are the
>abnormal and fault conditions?
>- Even if the standard would only require testing at 25 C, you need to
>consider that a car charger will be used at much higher ambient
>temperatures. Have you done a hazard analysis based on the specific use of
>this device?
>- Will elevated temperatures on the charger result in customer
>complaints? If the charger gets very hot, will it be perceived as unsafe?
>
>
>
> Ted Eckert
>
> The opinions expressed are my own and do not necessarily reflect those of
> my employer, TC 108 or the Society of Automotive Engineers.
>
>
>
> *From:* Scott Xe 
> *Sent:* Thursday, September 2, 2021 6:02 AM
> *To:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Subject:* [EXTERNAL] [PSES] Touch temperature limits for accessible parts
>
>
>
> I am looking for advice on temp measurements and the requirements. I have
> an in-car charger with a temp of 80 degC on external plastic enclosure at
> max load.

Re: [PSES] Touch temperature limits for accessible parts

[Scott Xe]

Dear Rich,

44 degC causing 1st degree skin burn is new to me and easy to get in touch
with this temperature in daily life.  I am looking forward to receiving
your paper and learning this matter in greater depth!

Many thanks & kindest regards,

Scott

On Fri, 3 Sept 2021 at 00:44, Richard Nute  wrote:

>
>
> Hi Scott:
>
>
>
> A 1st degree skin burn occurs when skin temperature is 44 C.  Plastic
> material has relatively high thermal resistance.  80 C plastic is unlikely
> to cause a burn regardless of contact time.  In a separate message, I will
> send separately my paper on thermal injury from the 2014 ISPCE.  From this
> you can calculate whether or not a burn will occur.
>
>
>
> Stay safe, and best regards,
>
> Rich
>
>
>
> Ps:  A charger running at more than 80 C is poorly designed.
>
>
>
>
>
> *From:* Scott Xe 
> *Sent:* Thursday, September 2, 2021 6:02 AM
> *To:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Subject:* [PSES] Touch temperature limits for accessible parts
>
>
>
> I am looking for advice on temp measurements and the requirements. I have
> an in-car charger with a temp of 80 degC on external plastic enclosure at
> max load.  Referring to EN 62368-1, the max temp is from 48 - 94 degC
> depending on the time to be touched to operate the equipment.  During
> operation, it is unnecessary to touch the external enclosure except
> plugging in and taking out from cigarette socket.  Is it deemed to apply 94
> degC?
>
>
>
> Should the max temp be measured at room temp of 25 degC or the maximum
> operating temp?  If at max operating temp, how to derive the max temp
> limits in such conditions?
>
>
>
> Thanks and regards,
>
>
>
> Scott
>

-

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Re: [PSES] Touch temperature limits for accessible parts

[Scott Xe]

Dear Doug,

Thanks for your references!  I will try to obtain those references for
study.

Cheers!

Scott

On Thu, 2 Sept 2021 at 22:34, Doug Nix  wrote:

> Hey Scott,
>
> You might want to have a look at
>
> EN 563, Safety of Machinery—Temperatures of touchable surfaces—Ergonomics
> data to establish temp. limits
> EN 13202, ERGONOMICS OF THE THERMAL ENVIRONMENT - TEMPERATURES OF
> TOUCHABLE HOT SURFACES - GUIDANCE FOR ESTABLISHING SURFACE TEMPERATURE
> LIMIT VALUES IN PRODUCT STANDARDS WITH THE AID OF EN 563
>
> ISO 13732-1:2006, Ergonomics of the thermal environment — Methods for the
> assessment of human responses to contact with surfaces — Part 1: Hot
> surfaces
>
> Doug Nix
> d...@ieee.org
> +1 (519) 729-5704
>
> On 2-Sep-21, at 09:02, Scott Xe  wrote:
>
> I am looking for advice on temp measurements and the requirements. I have
> an in-car charger with a temp of 80 degC on external plastic enclosure at
> max load.  Referring to EN 62368-1, the max temp is from 48 - 94 degC
> depending on the time to be touched to operate the equipment.  During
> operation, it is unnecessary to touch the external enclosure except
> plugging in and taking out from cigarette socket.  Is it deemed to apply 94
> degC?
>
>
> Should the max temp be measured at room temp of 25 degC or the maximum
> operating temp?  If at max operating temp, how to derive the max temp
> limits in such conditions?
>
>
> Thanks and regards,
>
>
> Scott
> -
> 
>
> This message is from the IEEE Product Safety Engineering Society emc-pstc
> discussion list. To post a message to the list, send your e-mail to <
> emc-p...@ieee.org>
>
> All emc-pstc postings are archived and searchable on the web at:
> http://www.ieee-pses.org/emc-pstc.html
>
> Attachments are not permitted but the IEEE PSES Online Communities site at
> http://product-compliance.oc.ieee.org/ can be used for graphics (in
> well-used formats), large files, etc.
>
> Website: http://www.ieee-pses.org/
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Re: [PSES] [EXTERNAL] [PSES] Touch temperature limits for accessible parts

[Scott Xe]

Dear Ted,

Many thanks for your good considerations!  I need to re-assess this issue
inclusive of those conditions.  I have one conflicted point about the touch
temperature of 80 degC which is at full load.  As you may know it, the full
load may happen at the initial charging and the charging current will
gradually decrease.  In general, it may not be so hot in normal
conditions.  What is your view on this?

Kindest regards,

Scott

On Thu, 2 Sept 2021 at 21:43, Ted Eckert  wrote:

> Hello Scott,
>
>
>
> Touch temperatures are measured at an ambient of 25 C. However, there are
> a number of additional considerations.
>
>- What are normal operating conditions? Is it true that the user would
>never touch the charger while it is in operation? There is no chance that
>they would try to disconnected it from the car’s socket while it is at
>maximum temperature?
>- If the user could disconnect it, how long do they need to hold it to
>pull it out of the car’s socket? Consider all users. For example, somebody
>with arthritis and a poor grip might need more time to disconnect the
>charger.
>- Think about how TS2 limits apply to touch temperatures. What are the
>abnormal and fault conditions?
>- Even if the standard would only require testing at 25 C, you need to
>consider that a car charger will be used at much higher ambient
>temperatures. Have you done a hazard analysis based on the specific use of
>this device?
>- Will elevated temperatures on the charger result in customer
>complaints? If the charger gets very hot, will it be perceived as unsafe?
>
>
>
> Ted Eckert
>
> The opinions expressed are my own and do not necessarily reflect those of
> my employer, TC 108 or the Society of Automotive Engineers.
>
>
>
> *From:* Scott Xe 
> *Sent:* Thursday, September 2, 2021 6:02 AM
> *To:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Subject:* [EXTERNAL] [PSES] Touch temperature limits for accessible parts
>
>
>
> I am looking for advice on temp measurements and the requirements. I have
> an in-car charger with a temp of 80 degC on external plastic enclosure at
> max load.  Referring to EN 62368-1, the max temp is from 48 - 94 degC
> depending on the time to be touched to operate the equipment.  During
> operation, it is unnecessary to touch the external enclosure except
> plugging in and taking out from cigarette socket.  Is it deemed to apply 94
> degC?
>
>
>
> Should the max temp be measured at room temp of 25 degC or the maximum
> operating temp?  If at max operating temp, how to derive the max temp
> limits in such conditions?
>
>
>
> Thanks and regards,
>
>
>
> Scott
>
> -
> 
>
> This message is from the IEEE Product Safety Engineering Society emc-pstc
> discussion list. To post a message to the list, send your e-mail to <
> emc-p...@ieee.org>
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[PSES] Touch temperature limits for accessible parts

[Scott Xe]

I am looking for advice on temp measurements and the requirements. I have
an in-car charger with a temp of 80 degC on external plastic enclosure at
max load.  Referring to EN 62368-1, the max temp is from 48 - 94 degC
depending on the time to be touched to operate the equipment.  During
operation, it is unnecessary to touch the external enclosure except
plugging in and taking out from cigarette socket.  Is it deemed to apply 94
degC?



Should the max temp be measured at room temp of 25 degC or the maximum
operating temp?  If at max operating temp, how to derive the max temp
limits in such conditions?



Thanks and regards,



Scott

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[PSES] Placing on the market - EU market

[Scott Xe]

Dear All,

In Blue Guide, it explains "Placing a product on the market requires an
offer or an agreement (written or verbal) between two or more legal or
natural persons for the transfer of ownership, possession or any other
property right concerning the product in question after the stage of
manufacture has taken place. This transfer could be for payment or free of
charge. It does not require the physical handover of the product."

One of buyers suggests that a fully manufactured good is ‘placed on the
market’ when a written or verbal agreement (or offer of an agreement) to
transfer ownership or possession or other property rights in the product is
exchanged.

‘Placing a good on the market’ means each individual good, not a type of
good.  It does not require the physical transfer of the good.

You can usually provide proof of placing on the market on the basis of any
relevant document ordinarily used in business transactions, including:

   - contracts of sale concerning goods which have already been
   manufactured and meet the old legal requirements
   - invoices
   - documents concerning the shipping of goods for distribution

It sounds a bit ridiculous that the EU buyer may receive the goods from the
manufacturer in a third country before the deadline of new legislation but
still store it at their warehouse for later delivery to EU member
countries.  The goods are considered to be placed on the market before the
deadline even if they arrive in EU member countries after the deadline.
Difficult to understand this logic.  Can someone share the rationale behind
this interpretation.

Thanks and regards,

Scott

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Re: [PSES] Names & addresses of manufacturer & Authorised Representative

[Scott Xe]

Dear Bernd,

Appreciate & agree on your points of product specific directive that may
cause confusion!  Will avoid it

Kind regards,

Scott


On Thu, 15 Jul 2021 at 16:39, Dürrer Bernd  wrote:

> Dear Scott,
>
>
>
> a product may be in the scope of several directives, and you have to check
> the definition of the scope of each applicable directive whether your
> product is in its scope or not. Furthermore, there are several cases with
> specific provisions which directive has to be applied (e.g. for Machinery
> and Low Voltage Directive, Radio Equipment and Low Voltage and EMC
> Directive). The term “product specific directive” is misleading (for
> example, though USB devices are electronic products, they are not in the
> scope of LVD, but in the scope of GPSD). Please refer to the “Blue Guide” (
> https://ec.europa.eu/growth/content/%E2%80%98blue-guide%E2%80%99-implementation-eu-product-rules_en)
> for further guidance, especially clause 2.6 “SIMULTANEOUS APPLICATION OF
> UNION HARMONISATION ACTS”.
>
>
>
> Kind regards,
>
>
>
> Bernd
>
>
>
> *Von:* Scott Xe 
> *Gesendet:* Montag, 12. Juli 2021 16:52
> *An:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Betreff:* Re: [PSES] Names & addresses of manufacturer & Authorised
> Representative
>
>
>
> Dear  Bernd,
>
>
>
> Many thanks for your cristal clear reply!!  Is there any relationship
> between GPSD and product specific directive?  If the product falls into
> product specific directive, the product shall meet the product specific
> directive only or the product specific directive and GPSD?  Learn a new
> draft GPSR has been published, will it bring a new relationship between
> product specific directive and GPSR?
>
>
>
> Best regards,
>
>
>
> Scott
>
>
>
> On Mon, 12 Jul 2021 at 21:47, Dürrer Bernd  wrote:
>
> Hello Scott,
>
>
>
> any consumer product is in the scope of Directive 2001/95/EC of the
> European Parliament and of the Council of 3 December 2001 on general
> product safety (
> https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32001L0095
> <https://eur01.safelinks.protection.outlook.com/?url=https%3A%2F%2Feur-lex.europa.eu%2Flegal-content%2FEN%2FTXT%2F%3Furi%3DCELEX%3A32001L0095=04%7C01%7C%7C76c378f6d51c41bd772908d945449d0a%7C39288a38ff19432c80111cd9d0dff445%7C0%7C0%7C637616983254735285%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C1000=y7%2Ba%2Bq1oLKWSOKRTVzssSlKN2rxIZrKq0BucB%2FDDnBc%3D=0>).
> Article 5 requires “an indication, by means of the product or its
> packaging, of the identity and details of the producer and the product
> reference or, where applicable, the batch of products to which it belongs”.
> As defined in Article 2, “producer” is either the manufacturer, the
> manufacturer’s representative, the importer, or other professionals in the
> supply chain.
>
>
>
> Kind regards,
>
>
>
> Bernd
>
>
>
> *Von:* Scott Xe 
> *Gesendet:* Montag, 12. Juli 2021 15:36
> *An:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Betreff:* [PSES] Names & addresses of manufacturer & Authorised
> Representative
>
>
>
> Products for EU market need to have name & address of manufacturer &
> authorised representative on the product.  I notice it is clear
> requirements in LVD, EMC, ErP, RoHS, etc. legislation.  Sounds for
> electrical products only.  For non electrical products, why don't they need
> it?  In case of any failure, to whom should the customers contact?  It
> seems the requirement is inconsistent with all consumer goods.
>
>
>
> Thanks and regards
>
>
>
> Scott
>
> -
> 
>
> This message is from the IEEE Product Safety Engineering Society emc-pstc
> discussion list. To post a message to the list, send your e-mail to <
> emc-p...@ieee.org>
>
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> <https://eur01.safelinks.protection.outlook.com/?url=http%3A%2F%2Fwww.ieee-pses.org%2Femc-pstc.html=04%7C01%7C%7C76c378f6d51c41bd772908d945449d0a%7C39288a38ff19432c80111cd9d0dff445%7C0%7C0%7C637616983254745243%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C1000=7WCPaq61HDlo1KYwBBPbuXy5u1s7tCaLXU87Ln8NU8Y%3D=0>
>
> Attachments are not permitted but the IEEE PSES Online Communities site at
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Re: [PSES] Names & addresses of manufacturer & Authorised Representative

[Scott Xe]

Dear  Bernd,

Many thanks for your cristal clear reply!!  Is there any relationship
between GPSD and product specific directive?  If the product falls into
product specific directive, the product shall meet the product specific
directive only or the product specific directive and GPSD?  Learn a new
draft GPSR has been published, will it bring a new relationship between
product specific directive and GPSR?

Best regards,

Scott

On Mon, 12 Jul 2021 at 21:47, Dürrer Bernd  wrote:

> Hello Scott,
>
>
>
> any consumer product is in the scope of Directive 2001/95/EC of the
> European Parliament and of the Council of 3 December 2001 on general
> product safety (
> https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32001L0095).
> Article 5 requires “an indication, by means of the product or its
> packaging, of the identity and details of the producer and the product
> reference or, where applicable, the batch of products to which it belongs”.
> As defined in Article 2, “producer” is either the manufacturer, the
> manufacturer’s representative, the importer, or other professionals in the
> supply chain.
>
>
>
> Kind regards,
>
>
>
> Bernd
>
>
>
> *Von:* Scott Xe 
> *Gesendet:* Montag, 12. Juli 2021 15:36
> *An:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Betreff:* [PSES] Names & addresses of manufacturer & Authorised
> Representative
>
>
>
> Products for EU market need to have name & address of manufacturer &
> authorised representative on the product.  I notice it is clear
> requirements in LVD, EMC, ErP, RoHS, etc. legislation.  Sounds for
> electrical products only.  For non electrical products, why don't they need
> it?  In case of any failure, to whom should the customers contact?  It
> seems the requirement is inconsistent with all consumer goods.
>
>
>
> Thanks and regards
>
>
>
> Scott
>
> -
> 
>
> This message is from the IEEE Product Safety Engineering Society emc-pstc
> discussion list. To post a message to the list, send your e-mail to <
> emc-p...@ieee.org>
>
> All emc-pstc postings are archived and searchable on the web at:
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>
> Attachments are not permitted but the IEEE PSES Online Communities site at
> http://product-compliance.oc.ieee.org/
> <https://eur01.safelinks.protection.outlook.com/?url=http%3A%2F%2Fproduct-compliance.oc.ieee.org%2F=04%7C01%7C%7C635e1fb9f4724b8a77e108d9453a07f6%7C39288a38ff19432c80111cd9d0dff445%7C0%7C0%7C637616937805003412%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C1000=%2BhOCQoZsMEEBBJesDNAi0vn5yUCSA8RNPklZUFWUV9Y%3D=0>
> can be used for graphics (in well-used formats), large files, etc.
>
> Website: http://www.ieee-pses.org/
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> <https://qr.wilo.com/wilo-world>
> --
>
> WILO SE
> Wilopark 1, 44263 Dortmund
> Amtsgericht Dortmund, HRB 21356
> www.wilo.com
>
> Vorstand/Executi

[PSES] Names & addresses of manufacturer & Authorised Representative

[Scott Xe]

Products for EU market need to have name & address of manufacturer &
authorised representative on the product.  I notice it is clear
requirements in LVD, EMC, ErP, RoHS, etc. legislation.  Sounds for
electrical products only.  For non electrical products, why don't they need
it?  In case of any failure, to whom should the customers contact?  It
seems the requirement is inconsistent with all consumer goods.

Thanks and regards

Scott

>

-

This message is from the IEEE Product Safety Engineering Society emc-pstc 
discussion list. To post a message to the list, send your e-mail to 


All emc-pstc postings are archived and searchable on the web at:
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Attachments are not permitted but the IEEE PSES Online Communities site at 
http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used 
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David Heald: 

Re: [PSES] Friday question

[Scott Xe]

Dear Doug,

Very interesting question and I would like to know it as well.  Suggest to
go to the testing lab for the answer.  They should have the statistics in
their business.

Would you mind sharing why you want to know it, what for?  Although I do
not have the figures I am aware of the answers why the product cannot pass
the test in the first attempt.  Below is my experience in dealing with
Asian suppliers in the past many years.

   - No safety engineer to go thru the design against the applicable
   standards before submitted for testing.
   - No proper facilities to conduct the pre-tests.
   - The employer does not recognise the importance of this position and
   results in no safety engineer in the manufacturer.  The design engineer is
   also not brave enough to tell the employer that they do not have knowledge,
   experience and test facilities in doing the relevant test work so the
   employer believes he/she looks after this as well.
   - The design engineer does not have relevant knowledge and training for
   the test work.  There is little education system in current
   universities/vocational institutes to help the society.  Most test
   engineers in public test labs are trained by the employers, not from the
   current educational system.  Some small associations (TIC - Testing,
   Inspection & Certification) from the industry are setting up routes to be
   certified testing professionals in the current educational system with the
   help from the Government Industry Department.  Just some improvement but
   not sufficient IMO!

Based on the above facts, it leads to other potential issues in the
finished products.  Even if the product has passed the conformity test, the
manufacturer may not know why their design meets the requirements.  How can
they maintain the compliance in production?  If the manufacturer does not
have this knowledge, how can they plan their assurance protocol for mass
production in order to validate the finished products in compliance with
the original design limits before leaving the factory?

Best regards, ☺

Scott

On Sat, 26 Jun 2021 at 01:56, Douglas E Powell  wrote:

> Out of curiosity,
>
> I would like to know (especially from those who have been in the business
> for a while) what is your "first pass success rate" for safety
> certifications on new product introductions? That is, to achieve a product
> safety certification from an accredited laboratory with no action items
> required coming out of the preliminary design review.  It's helpful if you
> can indicate how complex the projects are.
>
> In my 26 years as a compliance engineer, I've observed possibly three in
> total for products with a reasonably high complexity.
>
> Thanks! Doug
> --
>
> Douglas E Powell
> doug...@gmail.com
> http://www.linkedin.com/in/dougp01
>
> -
> 
>
> This message is from the IEEE Product Safety Engineering Society emc-pstc
> discussion list. To post a message to the list, send your e-mail to 
> emc-p...@ieee.org
>
> All emc-pstc postings are archived and searchable on the web at:
> http://www.ieee-pses.org/emc-pstc.html
>
> Attachments are not permitted but the IEEE PSES Online Communities site at
> http://product-compliance.oc.ieee.org/ can be used for graphics (in
> well-used formats), large files, etc.
>
> Website: http://www.ieee-pses.org/
> Instructions: http://www.ieee-pses.org/list.html (including how to
> unsubscribe) 
> List rules: http://www.ieee-pses.org/listrules.html
>
> For help, send mail to the list administrators:
> Scott Douglas sdoug...@ieee.org
> Mike Cantwell mcantw...@ieee.org
>
> For policy questions, send mail to:
> Jim Bacher j.bac...@ieee.org
> David Heald dhe...@gmail.com
>

-

This message is from the IEEE Product Safety Engineering Society emc-pstc 
discussion list. To post a message to the list, send your e-mail to 


All emc-pstc postings are archived and searchable on the web at:
http://www.ieee-pses.org/emc-pstc.html

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http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used 
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Mike Cantwell 

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David Heald: 

Re: [PSES] Demonstrating Compliance to the LVD w/o using 62368

[Scott Xe]

Hi Daniel,

Your logic makes sense but we may receive the challenge from MSA who will
follow the harmonised standards published in OJEU at the time of their
survey.  In case the latest version is relaxed as compared with the current
version.  You may be in trouble!

Regards,

Scott


On Thu, 17 Jun 2021 at 20:08, Rodriguez, Daniel (ESP) <
123de38bd494-dmarc-requ...@listserv.ieee.org> wrote:

> Sorry to reopen this topic
> The question is the version to apply for EU testing?
> 1-Last harmonized version is EN IEC 62368-1:2014+AC:2015
> 2-Last available version is EN IEC 62368-1:2020+A11:2020
>
> Which one shall we test? The equivalent IEC are IEC 62368-1:2014 (ED.
> 2.0) and IEC 62368-1:2018 (ED. 3.0)?
> My preference is to test the last available version to avoid future
> retesting next years
>
> Thank you for your answers.
>
> Kind Regards / Saludos cordiales / Mit freundlichen Grüßen
>
>
>
> *Daniel Rodríguez *
>
> Sr. Equipment Compliance Specialist EMEA
>
>
>
> --
> *From:* Ted Eckert <07cf6ebeab9d-dmarc-requ...@listserv.ieee.org>
> *Sent:* Thursday, September 17, 2020 9:56 PM
> *To:* EMC-PSTC@LISTSERV.IEEE.ORG 
> *Subject:* Re: [PSES] Demonstrating Compliance to the LVD w/o using 62368
>
> *Caution:* This email message originated from outside of the
> organization. *DO NOT CLICK* on links or open attachments unless you
> recognize the sender and know the content is safe. If you think it is
> suspicious, please *report as suspicious*.
>
> Hi Chuck,
>
>
>
> The biggest change that I have seen is for touch temperatures. IEC 60950-1
> allows continuous contact with plastic at 75 C. Even glass is allows a
> continuous temperature of 70 C. Imagine using one of those new glass-bodied
> cell phones with it at that temperature. IEC 62368-1 reduces the continuous
> contact temperature limit to 48 C for all materials.
>
>
>
> There were probably many older laptop computers with plastic cases that
> could exceed 48 C on the bottom surface during use. Those laptops would not
> comply with IEC 62368-1.
>
>
>
> This isn’t the only item to consider, but it’s the one I’m most familiar
> with. There are additional issues related to fire enclosures where a
> product could pass IEC 60950-1 but fail IEC 62368-1 2nd Edition. However,
> these issues have largely be resolved with IEC 62368-1 3rd edition. TC
> 108 recognized that there were many constructions allowed under IEC 60950-1
> that were shown to be acceptable through years of use, yet disallowed by
> IEC 62368-1 2nd edition. Many issues were resolved with the update.
>
>
>
> Ted Eckert
>
> Microsoft Corporation
>
>
>
> The opinions experessed are my own and do not necessarily reflect those of
> my employer or TC 108.
>
>
>
>
>
>
>
> *From:* Chuck August-McDowell 
> *Sent:* Thursday, September 17, 2020 11:33 AM
> *To:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Subject:* [EXTERNAL] Re: [PSES] Demonstrating Compliance to the LVD w/o
> using 62368
>
>
>
> Hi Charles,
>
>
>
> Only slightly off your topic “Has anyone experienced having an ITE product
> that complies with IEC60950 requirements, but does not comply with some
> portions IEC 62368?“
>
> I work on the audio side so our base standard is 60065. So to rephrase the
> question;
>
> “Has anyone experienced having an audio product that complies with IEC
> 60065 requirements, but does not comply with some portions IEC 62368? “
>
> I was informed during factory audit the Hipot test voltage changed from
> 1500 VAC to 1768 VAC ?
>
>
>
> Oh, and outdoor use also changes from IEC 62368 2ed, calls for using
> 60950-22 at current editions, which the 2005 edition did not require a dust
> test, but new (required) 2nd edition requires a dust test, where as 60065
> required only IPX4 testing.
>
>
>
> Let the testing begin!
>
>
>
> Respectfully,
>
>
>
> Chuck August-McDowell
>
>
>
>
>
> *From:* Charles Jackson 
> *Sent:* Wednesday, September 16, 2020 7:57 AM
> *To:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Subject:* [PSES] Demonstrating Compliance to the LVD w/o using 62368
>
>
>
> [EXTERNAL EMAIL]
>
> Has anyone experienced having an ITE product that complies with IEC60950
> requirements, but does not comply with some portions IEC 62368?  In
> particular the use of a non-LPS psu.  Is there some sort of risk analysis
> that can be done to prove up conformance to the directive based on 60950
> with or without supplemental test??
>
>
>
> Thanks in advance
>
> Chuck
>
> -
> 
>
> This message is from the IEEE Product Safety Engineering Society emc-pstc
> discussion list. To post a message to the list, send your e-mail to <
> emc-p...@ieee.org>
>
> All emc-pstc postings are archived and searchable on the web at:
> http://www.ieee-pses.org/emc-pstc.html
> 

Re: [PSES] CE Test Report for UK Compliance?

[Scott Xe]

Hi Andy,

The notified body is required in a few legislations without
harmonised standards for certain products, such as RED.  In the UK, it is
now called Approved Body.

Regards,

Scott


On Sun, 20 Jun 2021 at 03:48, Charlie Blackham 
wrote:

> Darren
>
>
>
> The “Conformity Assessment Body” is the Notified Body (EU) of Competent
> Body (UK)
>
>
>
> This advice isn’t as clearly written as it could be – that last sentence
> has nothing to do with product testing or test labs
>
>
>
> Best regards
>
> Charlie
>
>
>
> *Charlie Blackham*
>
> *Sulis Consultants Ltd*
>
> *Tel: +44 (0)7946 624317*
>
> *Web: https://sulisconsultants.com/  *
>
> Registered in England and Wales, number 05466247
>
>
>
> *From:* Darren @ Vitesses 
> *Sent:* 19 June 2021 13:20
> *To:* Charlie Blackham 
> *Cc:* EMC-PSTC@listserv.ieee.org
> *Subject:* Re: [PSES] CE Test Report for UK Compliance?
>
>
>
> Hi Charles
>
> Can you explain your last sentence, “ the conformity assessment bodies
> that test them need to be different”
>
>
>
> From my understanding a test lab can test to mutiple country standards and
> results used,  ssuming its self declaration .
>
>
>
> Sent from my iPhone
>
>
>
> On 19 Jun 2021, at 12:44, Charlie Blackham 
> wrote:
>
> 
>
> Andy
>
>
>
> > some folks are asking for a UK test report
>
>
>
> Some folks are confused then 
>
>
> https://www.gov.uk/guidance/placing-manufactured-goods-on-the-market-in-great-britain
>
>
>
> *Using both the CE and UKCA marking*
>
> Both the CE and UKCA mark can be placed on a product so long as neither
> impedes the visibility of the other and requirements of both
> the GB and EU legislation are met.
>
> The essential requirements and standards that can be used to demonstrate
> conformity with them for UKCA marked goods have not changed. That means
> that if your good is currently made to the technical requirements necessary
> for CE marking then it will be made to the same technical requirements that
> exist for UKCA marking. However, the conformity assessment bodies that test
> them may need to be different.
>
> Best regards
>
> Charlie
>
>
>
> *Charlie Blackham*
>
> *Sulis Consultants Ltd*
>
> *Tel: +44 (0)7946 624317*
>
> *Web: https://sulisconsultants.com/  *
>
> Registered in England and Wales, number 05466247
>
>
>
> *From:* worldwideemc 
> *Sent:* 18 June 2021 19:57
> *To:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Subject:* Re: [PSES] CE Test Report for UK Compliance?
>
>
>
> Hi Darren,
>
>
>
> Thank you for the information. It makes sense that the CE report should be
> sufficient but some folks are asking for a UK test report. I believe I'm
> not the only one confused on this topic.
>
>
>
> BR,
>
> Andy
>
>
>
> On Fri, Jun 18, 2021 at 11:38 AM Darren @ Vitesses <
> vites...@btinternet.com> wrote:
>
> Hi Andy
>
>
>
> Yes
>
> If the reports show you meet the relevant standards that would be fine
>
> But also many international standards are the same, eg the Aus/NZS
> standard has a different name but the set up and limits are identical.
>
> So a report to thoes standards would support a claim of compliance to the
> en standards regardless of the country.
>
>
>
> I would recommend drawing up a document explaining the reasoning behind
> it.
>
>
>
> Regards Darren
>
> Sent from my iPhone
>
>
>
>
> On 18 Jun 2021, at 18:28, worldwideemc  wrote:
>
> 
>
> Hello All,
>
>
>
> Can I use my European EMC test report to claim compliance to UK
> regulations? I understand I need to generate a UKCA DoC and apply the UKCA
> marking.
>
>
>
> The UK designated standards list at the link below lists EN standards
> without any reference to a British Standard...
>
>
>
>
> https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/942100/ds-0007-21-emc-notice.pdf
> .
>
>
>
> Any input from the list experts would be appreciated!
>
>
> --
>
> BR,
> Andy Parker
>
> -
> 
>
> This message is from the IEEE Product Safety Engineering Society emc-pstc
> discussion list. To post a message to the list, send your e-mail to <
> emc-p...@ieee.org>
>
> All emc-pstc postings are archived and searchable on the web at:
> http://www.ieee-pses.org/emc-pstc.html
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> --
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> Regards,
> Andrew Parker
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> 
>
> This message is from the IEEE Product 

Re: [PSES] CE Test Report for UK Compliance?

[Scott Xe]

Hi Andy,

On this case, you can check the designed standards against the EU
compliance test report and reach a conclusion in compliance with UK
legislation.  You did it for the test lab on this case.  For other
legislation requiring BS standards, do you have the knowledge to do the
same?  Normally the test lab must find out the correct designed standards
for complying UK legislation for you.  In the future, UK may have their own
standards different from the EU.  Are you monitoring it closely to maintain
an updated list for your checks?  You have to take note of this risk.

Regards,

Scott

On Sat, 19 Jun 2021 at 01:28, worldwideemc  wrote:

> Hello All,
>
> Can I use my European EMC test report to claim compliance to UK
> regulations? I understand I need to generate a UKCA DoC and apply the UKCA
> marking.
>
> The UK designated standards list at the link below lists EN standards
> without any reference to a British Standard...
>
>
> https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/942100/ds-0007-21-emc-notice.pdf
> .
>
> Any input from the list experts would be appreciated!
>
> --
> BR,
> Andy Parker
> -
> 
>
> This message is from the IEEE Product Safety Engineering Society emc-pstc
> discussion list. To post a message to the list, send your e-mail to 
> emc-p...@ieee.org
>
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Re: [PSES] Hot surface sign

[Scott Xe]

Dear Josh,

Although the contrast of warning size is not perfect, there is no specific
requirement given and common on the product.

Regards,

Scott

On Wed, 26 May 2021 at 22:14, Wiseman, Joshua <
joshua.wise...@orthoclinicaldiagnostics.com> wrote:

> Scott,
>
>
>
> At my previous employer we had the symbol stamped into the stainless steel
> of a part on the commercial griddle. A traditional label would not
> withstand the heat in this instance and with-it being part of the sheet
> metal it me all the cleaning and legibility requirements. It’s hard to see
> but I took a snippet of one from a video of the griddle on YouTube.
>
>
>
>
>
> Josh
>
>
>
> *Joshua Wiseman*
>
> Staff Engineer, Product Safety/EMC/Systems
>
>
>
> *From:* Scott Xe 
> *Sent:* Wednesday, May 26, 2021 10:04 AM
> *To:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Subject:* [PSES] Hot surface sign
>
>
>
> *EXTERNAL SENDER: Verify links, attachments and sender before taking
> action*
>
>
>
> In some cooking appliances, there are some hot surfaces that may cause
> burn injury and safety standards suggest putting a hot surface sign to
> alert the users.
>
>- Is there any specific colour requirement?  Common practice is black
>colour on yellow background or white colour on black background.
>- Is an embossed sign black on black considered as a legible sign in
>EU criteria perspective?
>- In case of ink-printed label, is it put on the top of the hot
>surface or next to the hot surface?  If on the top of surface, the colours
>are protected from heat degradation and specialized adhesives should be
>used to withstand higher temperatures.  Is there any test criteria for
>verification?
>
> Thanks and regards,
>
>
>
> Scott
>
> -
> 
>
> This message is from the IEEE Product Safety Engineering Society emc-pstc
> discussion list. To post a message to the list, send your e-mail to <
> emc-p...@ieee.org>
>
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> can be used for graphics (in well-used formats), large files, etc.
>
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-
-

Re: [PSES] Hot surface sign

[Scott Xe]

Dear Charlie,

Thanks for the useful information!  I really discover such sign is commonly
on MWOs, induction cookers, sandwich makers, etc.  The document contains
greater detail about this sign.

Best regards,

Scott

On Thu, 27 May 2021 at 03:19, Charlie Blackham 
wrote:

> Scott
>
>
>
> I’ve not read it (44 pages) but EU LVD market enforcement did a report 
> “Non-functional
> Hot Surfaces Project”
>
>
>
> https://ec.europa.eu/docsroom/documents/5263/attachments/1/translations
>
>
>
> Some standards, such as EN 60335-2-9 (Household and similar electrical
> appliances - Safety - Part 2-9: Particular requirements for grills,
> toasters and similar portable cooking appliances) have different limits if
> equipment is labelled
>
>
>
> The ISO symbol IEC 60417 - 5041, Caution, hot surface (iso.org)
> <https://www.iso.org/obp/ui#iec:grs:60417:5041>, is often referred to,
> but I’m not aware that colours or contrast is mandated
>
>
>
> Best regards
>
> Charlie
>
>
>
> *Charlie Blackham*
>
> *Sulis Consultants Ltd*
>
> *Tel: +44 (0)7946 624317*
>
> *Web: https://sulisconsultants.com/ <https://sulisconsultants.com/> *
>
> Registered in England and Wales, number 05466247
>
>
>
> *From:* Brian Kunde 
> *Sent:* 26 May 2021 18:08
> *To:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Subject:* Re: [PSES] Hot surface sign
>
>
>
> Usually, high-temperature surface warning symbols are only required if the
> hazard is not obvious.  So in ovens, stovetops, griddles, toasters,
> heat-sinks, etc. do not require them.
>
>
>
> However, if such appliances or device have areas that are hot but it is
> not obvious it is hot, a warning symbol might be required.
>
>
>
> At home, I have a 2-slice toaster. It is a "Cool Touch" toaster that has
> no hot exposed surfaces, except from the small surface between the two
> slots on the top.  So the manufacturer engraved the symbol on the metal
> surface.  Not a bad idea.  But back in the day, the sides of a toaster got
> really hot; hot enough to melt the Wonder Bread bag.  As a kid, I think
> every toaster I ever saw had a Wonder Bread bag melted on the side.
>
>
>
> The Other Brian
>
>
>
> On Wed, May 26, 2021 at 10:04 AM Scott Xe  wrote:
>
> In some cooking appliances, there are some hot surfaces that may cause
> burn injury and safety standards suggest putting a hot surface sign to
> alert the users.
>
>- Is there any specific colour requirement?  Common practice is black
>colour on yellow background or white colour on black background.
>- Is an embossed sign black on black considered as a legible sign in
>EU criteria perspective?
>- In case of ink-printed label, is it put on the top of the hot
>surface or next to the hot surface?  If on the top of surface, the colours
>are protected from heat degradation and specialized adhesives should be
>used to withstand higher temperatures.  Is there any test criteria for
>verification?
>
> Thanks and regards,
>
>
>
> Scott
>
> -
> 
>
> This message is from the IEEE Product Safety Engineering Society emc-pstc
> discussion list. To post a message to the list, send your e-mail to 
> emc-p...@ieee.org
>
> All emc-pstc postings are archived and searchable on the web at:
> http://www.ieee-pses.org/emc-pstc.html
>
> Attachments are not permitted but the IEEE PSES Online Communities site at
> http://product-compliance.oc.ieee.org/ can be used for graphics (in
> well-used formats), large files, etc.
>
> Website: http://www.ieee-pses.org/
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>
> -
> 
>
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> discussion list. To post a message to the list, send your e-mail to <
> emc-p...@ieee.org>
>
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> http://www.ieee-pses.org/emc-pstc.html
>
> Attachments are not permitted but the IEEE PSES Online Communities site at
> http://product-compliance.oc.ieee.org/ can be used for graphics (in
> well-used formats), large files, etc.
>
> Website: http://www.ieee-pses.org/
> Instructions: http:

[PSES] Hot surface sign

[Scott Xe]

In some cooking appliances, there are some hot surfaces that may cause burn
injury and safety standards suggest putting a hot surface sign to alert
the users.

   - Is there any specific colour requirement?  Common practice is black
   colour on yellow background or white colour on black background.
   - Is an embossed sign black on black considered as a legible sign in EU
   criteria perspective?
   - In case of ink-printed label, is it put on the top of the hot surface
   or next to the hot surface?  If on the top of surface, the colours are
   protected from heat degradation and specialized adhesives should be used to
   withstand higher temperatures.  Is there any test criteria for verification?

Thanks and regards,

Scott

-

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Re: [PSES] EU Machinery Directive 2006/42/EC for motorized adjustable height table

[Scott Xe]

Dear Pete,

The DoC included in IB is required by MD like RED.  No idea why only these
two directives are required in IB.  Normal customers might not know
what they are.  It is more appropriate in the technical file to be checked
by MSA upon request.

Thanks and regards,

Scott


On Wed, 5 May 2021 at 03:29, Pete Perkins  wrote:

> Scott,The MDoC and other public references to standards used become an
> overload in the supplied documentation.  The better route is to incorporate
> these references, detailing by clause and/or whatever limitation you have
> applied, in your Technical File which supports the claim of meeting EN ISO
> 12100 in the MDoC and manual provided.
>
>
>
> :>) br,  Pete
>
>
>
> Peter E Perkins, PE
>
> Principal Product Safety & Regulatory Affairs Consultant
>
> PO Box 1067
>
> Albany, ORe  97321-0413
>
>
>
> 503/452-1201
>
>
>
> IEEE Life Fellow
>
> IEEE PSES 2020 Distinguished Lecturer
>
> www.researchgate.net <http://www.researchgate.net/Peter%20Perkins> search
> my name
>
> p.perk...@ieee.org
>
>
>
>
>
> Entropy ain’t what it used to be
>
>
>
> *From:* Scott Xe 
> *Sent:* Tuesday, May 4, 2021 7:51 AM
> *To:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Subject:* [PSES] EU Machinery Directive 2006/42/EC for motorized
> adjustable height table
>
>
>
> It applies the harmonised standard EN ISO 12100 to assess the product for
> the compliance of MD.  In the conformity report, it validates each clause
> using a few standards such as EN 60335-1, EN 527, EN 55014-1:2017+A11:2020,
> EN 61000-3-2:2019, EN 62233 : 2008 etc.  Is it necessary to quote all the
> standards or just EN ISO 12100 only in the DoC inside the instructions
> manual?
>
>
>
> Thanks and regards,
>
>
>
> Scott
>
> -
> 
>
> This message is from the IEEE Product Safety Engineering Society emc-pstc
> discussion list. To post a message to the list, send your e-mail to <
> emc-p...@ieee.org>
>
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Re: [PSES] EU Machinery Directive 2006/42/EC for motorized adjustable height table

[Scott Xe]

Dear Mike,

I agree with you.  Probably the DoC was made reference to another sample.

Thanks and regards,

Scott

On Wed, 5 May 2021 at 00:22, MIKE SHERMAN  wrote:

> Scott --
> 1.  I tend to not list a harmonized standard unless I've applied all of
> its requirements to my machine.
> 2.  Some of the standards you mention are for EMC, not MD.
>
> Mike
>
> On 05/04/2021 9:51 AM Scott Xe  wrote:
>
>
>
> It applies the harmonised standard EN ISO 12100 to assess the product for
> the compliance of MD.  In the conformity report, it validates each clause
> using a few standards such as EN 60335-1, EN 527, EN 55014-1:2017+A11:2020,
> EN 61000-3-2:2019, EN 62233 : 2008 etc.  Is it necessary to quote all the
> standards or just EN ISO 12100 only in the DoC inside the instructions
> manual?
>
> Thanks and regards,
>
> Scott
> -
> 
>
> This message is from the IEEE Product Safety Engineering Society emc-pstc
> discussion list. To post a message to the list, send your e-mail to <
> emc-p...@ieee.org>
>
> All emc-pstc postings are archived and searchable on the web at:
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> Attachments are not permitted but the IEEE PSES Online Communities site at
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>
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> -
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>
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> All emc-pstc postings are archived and searchable on the web at:
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> Attachments are not permitted but the IEEE PSES Online Communities site at
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[PSES] EU Machinery Directive 2006/42/EC for motorized adjustable height table

[Scott Xe]

It applies the harmonised standard EN ISO 12100 to assess the product for
the compliance of MD.  In the conformity report, it validates each clause
using a few standards such as EN 60335-1, EN 527, EN 55014-1:2017+A11:2020,
EN 61000-3-2:2019, EN 62233 : 2008 etc.  Is it necessary to quote all the
standards or just EN ISO 12100 only in the DoC inside the instructions
manual?

Thanks and regards,

Scott

-

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Re: [PSES] EU Declaration of Conformity (DoC)

[Scott Xe]

Dear Charlie,

Thanks for your advice!  Does CE Mark link with DoC?  For example, REACH
regulation does not require CE Mark whereas it requires DoS.  For CE
Marking, does it require DoC?

On Thu, 25 Feb 2021 at 00:10, Charlie Blackham 
wrote:

> Scott
>
>
>
> The list of applicable Directives that are covered by CE marking can be
> found at
> https://ec.europa.eu/growth/single-market/ce-marking/manufacturers_en
>
>
>
> There are a number of other Directives and Regulations that may be
> mandatory for your product, but they are not covered by CE marking
>
>
>
> Best regards
>
> Charlie
>
>
>
> *Charlie Blackham*
>
> *Sulis Consultants Ltd*
>
> *Tel: +44 (0)7946 624317*
>
> *Web: https://sulisconsultants.com/ <https://sulisconsultants.com/> *
>
> Registered in England and Wales, number 05466247
>
>
>
> *From:* Scott Xe 
> *Sent:* 24 February 2021 13:46
> *To:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Subject:* [PSES] EU Declaration of Conformity (DoC)
>
>
>
> Does the DoC only provide references to the directives or regulations that
> require DoC?  Other non-required directives or regulations should not be
> included in the DoC.  For examples, GPSD, packaging waste, battery, energy
> label, etc.
>
>
>
> Thanks and regards,
>
>
>
> Scott
>
> -
> 
>
> This message is from the IEEE Product Safety Engineering Society emc-pstc
> discussion list. To post a message to the list, send your e-mail to <
> emc-p...@ieee.org>
>
> All emc-pstc postings are archived and searchable on the web at:
> http://www.ieee-pses.org/emc-pstc.html
>
> Attachments are not permitted but the IEEE PSES Online Communities site at
> http://product-compliance.oc.ieee.org/ can be used for graphics (in
> well-used formats), large files, etc.
>
> Website: http://www.ieee-pses.org/
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Re: [PSES] EU Declaration of Conformity (DoC)

[Scott Xe]

Hi Dan,

We put almost all applicable directives or regulations in one DoC for a
long period of time without any questions from MSAs.  It is a
common practice in the industry.  Recently we got an inquiry about
inadequacy of putting energy label regulation in the DoC and expect us to
remove it.  They are right that the energy label regulation does not
require DoC whereas the eco-design does.  Thus bring it up for comments
from the group.

On Wed, 24 Feb 2021 at 23:43, Dan Roman  wrote:

> Hi Scott,
>
>
>
> I think what you are really asking is what is the legally required
> minimum?  If yes, then Directives like the GPSD, which does not in its text
> require a DoC (or CE Marking), would not require a DoC and would not need
> to be listed on a DoC that may be issued to cover other Directives or
> Regulations.  I do not think though that there are restrictions that would
> prevent you from putting more than what is the minimum legal requirement
> should you desire to do so.  So I do not think that listing the GPSC on a
> DoC is illegal.  Would be interested in hearing from others on the topic
> though.
>
>
>
> Stay safe, stay well.
>
>
>
> Dan
>
>
>
> *From:* Scott Xe [mailto:scott...@gmail.com]
> *Sent:* Wednesday, February 24, 2021 8:46 AM
> *To:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Subject:* [PSES] EU Declaration of Conformity (DoC)
>
>
>
> Does the DoC only provide references to the directives or regulations that
> require DoC?  Other non-required directives or regulations should not be
> included in the DoC.  For examples, GPSD, packaging waste, battery, energy
> label, etc.
>
>
>
> Thanks and regards,
>
>
>
> Scott
>
> -
> 
>
> This message is from the IEEE Product Safety Engineering Society emc-pstc
> discussion list. To post a message to the list, send your e-mail to <
> emc-p...@ieee.org>
>
> All emc-pstc postings are archived and searchable on the web at:
> http://www.ieee-pses.org/emc-pstc.html
>
> Attachments are not permitted but the IEEE PSES Online Communities site at
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> well-used formats), large files, etc.
>
> Website: http://www.ieee-pses.org/
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[PSES] EU Declaration of Conformity (DoC)

[Scott Xe]

Does the DoC only provide references to the directives or regulations that
require DoC?  Other non-required directives or regulations should not be
included in the DoC.  For examples, GPSD, packaging waste, battery, energy
label, etc.

Thanks and regards,

Scott

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[PSES] Eco-design regulation EU 2019/2021 for Electronic Displays

[Scott Xe]

I have two questions about network interfaces on TVs.

1.  Is HDMI-CEC (Consumer Electronics Control) port classified as a network
interface like Ethernet or WiFi network interface?

2.  Shall HDMI-CEC port be disabled by default according to the regulation?

We received customers' inquiries/complaints to be required to activate this
feature manually and would like to know the background why this port is
disable by default although both enable and disable modes meet the power
consumption limits.  We have read the latest draft revision of 06/10/2020
but still no clue of this issue and seeking more details for compliance.

Thanks and regards,

Scott

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Re: [PSES] Correct interpretation of EN 60950-1 or EN 62368-1

[Scott Xe]

Dear Charlie,

Thanks for your reference and advice!  Obviously I did not notice this rule
existing for long.  Looking at USB external hard drives, printers, mobile
phones, card readers, scanners, etc. all do not have any power ratings.

Best regards,

Scott


On Tue, 24 Nov 2020 at 22:02, Charlie Blackham 
wrote:

> Scott
>
>
>
> Quote from PD IEC/TR 62368-2:2015, “*Audio/video, information and
> communication technology equipment Part 2: Explanatory information related
> to*
>
> *IEC 62368-1*”
>
>
>
> *Annex F Equipment markings, instructions, and instructional safeguards*
>
> *F.3 Equipment markings*
>
> Source: EC Directives such as 98/37/EC Machinery Directive, Annex I clause
> 1.7.3 marking; NFPA79:2002, clause 17.4 nameplate data; CSA C22.1 Canadian
> Electric Code, clause 2-100 marking of equipment give organized
> requirements. The requirements here are principally taken from IEC 60065 and
>
> IEC 60950 series.
>
>
>
> *F.3.3.2 Equipment without direct connection to mains*
>
> Source: IEC 60950-1
>
> Purpose: To clarify that equipment powered by mains circuits, but not
> directly connected to the mains using standard plugs and connectors, need
> not have an electrical rating.
>
> Rationale: Only equipment that is directly connected to the mains supplied
> from the building installation needs to have an electrical rating that
> takes into account the full load that may be connected to the building
> supply outlet. For equipment that is daisy-chained or involves a
> master-slave configuration, only the master unit or the first unit in the
> daisy chain needs to be marked
>
>
>
>
>
> Best regards
>
> Charlie
>
>
>
> *Charlie Blackham*
>
> *Sulis Consultants Ltd*
>
> *Tel: +44 (0)7946 624317*
>
> *Web: https://sulisconsultants.com/ <https://sulisconsultants.com/> *
>
> Registered in England and Wales, number 05466247
>
>
>
> *From:* Scott Xe 
> *Sent:* 24 November 2020 13:46
> *To:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Subject:* [PSES] Correct interpretation of EN 60950-1 or EN 62368-1
>
>
>
> Power rating under cl 1.7.1 of EN 60950-1 or cl F3.3 of EN 62368-1 states
> that "If a unit is not provided with a means for direct connection to a
> mains supply, it need not be marked with any electrical rating, such as its
> rated voltage, rated current or rated power."  In general, "input: 5 Vdc X
> A" is marked on the device.  We have a new USB device that does not have
> any rated marking on it and it comes with a conformity test report meeting
> EN 62368-1.  Doesn't a low voltage device have no potential safety issues?
> Can someone share any light of this interpretation or background.
>
>
>
> Thanks and regards,
>
>
>
> Scott
>
> -
> 
>
> This message is from the IEEE Product Safety Engineering Society emc-pstc
> discussion list. To post a message to the list, send your e-mail to <
> emc-p...@ieee.org>
>
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>
> Attachments are not permitted but the IEEE PSES Online Communities site at
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> well-used formats), large files, etc.
>
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>
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[PSES] Correct interpretation of EN 60950-1 or EN 62368-1

[Scott Xe]

Power rating under cl 1.7.1 of EN 60950-1 or cl F3.3 of EN 62368-1 states
that "If a unit is not provided with a means for direct connection to a
mains supply, it need not be marked with any electrical rating, such as its
rated voltage, rated current or rated power."  In general, "input: 5 Vdc X
A" is marked on the device.  We have a new USB device that does not have
any rated marking on it and it comes with a conformity test report meeting
EN 62368-1.  Doesn't a low voltage device have no potential safety issues?
Can someone share any light of this interpretation or background.

Thanks and regards,

Scott

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Re: [PSES] ROHS and DoC

[Scott Xe]

Brian,

 

My view is that is it necessary to do so?  When you sign a DoC for RoHS 
compliance, the product must fully comply with RoHS Directive 2011/65/EU (all 
amendments are included) at time of signing.  Otherwise it is not a correct 
DoC.  Although it does not reach the deadline now, you need to sign another one 
before the deadline replacing the current one when it will be becoming invalid. 
 RoHS Directive 2011/65/EU is the main directive and has many amendments, not 
only 2015/863/EU.  I did not see any DoCs with all amendments included.

 

Regards,

 

Scott

 

From: Brian Kunde  
Sent: Sunday, 22 November 2020 01:26 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] ROHS and DoC

 

Because we provide DoCs translated into over 30 languages, we try to avoid text 
that has to be translated. Our type of products do not have to comply with 
these new regulations until next year, but when we do, we plan to use the same 
nomenclature that is used for the amendments of Standards by using the Plus 
Sign (+). So under the RoHS Directive, we plan to list it like this:  

 

2011/65/EU + 2015/863

 

Does anyone see any issue with this?  

 

Regards,

The Other Brian

 

 

 

On Sat, Nov 21, 2020 at 4:26 PM Scott Douglas mailto:sdouglas...@gmail.com> > wrote:

I used to get complaints I was not up to date when I said 2011/65/EU as 
amended. Now I say 2011/65/EU as amended by 2015/863. No more complaints.

 

 

On Sat, Nov 21, 2020, 12:57 PM Charlie Blackham mailto:char...@sulisconsultants.com> > wrote:

Amund

Whilst 2015/863 updates 2011/65/EU, you do not CE mark to it. 
The DoC must be to 2011/65/EU

Some people concentrate a lot on 2015/863 but there have been far more 
Delegated Directives dealing with exemptions than just this one dealing with 
substances  (https://ec.europa.eu/environment/waste/rohs_eee/legis_en.htm)

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/ 
Registered in England and Wales, number 05466247

-Original Message-
From: Amund Westin mailto:am...@westin-emission.no> 
> 
Sent: 21 November 2020 10:01
To: EMC-PSTC@LISTSERV.IEEE.ORG  
Subject: [PSES] ROHS and DoC

For EU compliance, I assume Directive 2011/65/EU is still the correct reference 
to use?
I see several parties who is referring to 2015/863 in their DoC, but isn't that 
reference just a replacement for Annex II in 2011/65/EU?

Best regards
Amund

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[PSES] EMF harmonised standards

[Scott Xe]

I notice EN 62311 is commonly used for electrical appliances.  For AV/ITE
products, there are 3 standards: EN 50633, EN 62311 and EN 62479 to be
used.  Is there any solid guidance to select the correct standard for the
product category?

Thanks and regards,

Scott

>

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Re: [PSES] AW: [PSES] ErP Directive requiring CE Marking

[Scott Xe]

Dear Bernd,



Many thanks for your clear pointer!  I looked into the delegated
regulations incorrectly.



Best regards,



Scott



On Tue, 29 Sep 2020 at 14:24, Dürrer Bernd  wrote:

> Hi Scott,
>
> Article 5 of ErP Directive 2009/125/EC requires CE marking (
> https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32009L0125=EN#d1e903-10-1
> ).
>
> Kind regards,
>
> Bernd
> ------
> *Von:* Scott Xe 
> *Gesendet:* Dienstag, 29. September 2020 07:53
> *An:* EMC-PSTC@LISTSERV.IEEE.ORG 
> *Betreff:* [PSES] ErP Directive requiring CE Marking
>
> I have learnt that ErP Directive requires CE Marking as compliance with
> the Directive.  I could not find this requirement in the Directive like
> others such as LVD, EMC, etc.  Can someone advise if I got incorrect info
> or where to document this requirement.
>
> Thanks and regards,
>
> Scott
>
>
> -
> 
>
> This message is from the IEEE Product Safety Engineering Society emc-pstc
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[PSES] ErP Directive requiring CE Marking

[Scott Xe]

I have learnt that ErP Directive requires CE Marking as compliance with the
Directive.  I could not find this requirement in the Directive like others
such as LVD, EMC, etc.  Can someone advise if I got incorrect info or where
to document this requirement.

Thanks and regards,

Scott

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[PSES] Energy related Products (ErP) requirements

[Scott Xe]

I have some queries about the application of ErP requirements seeking
esteemed advice.  The following products are involved.

   1. TV + EPS (sold together)
   2. Mobile Phone + EPS (sold together)

For product 1, should ErP requirements for TV or EPS be applied or both.

For product 2, should ErP requirements for EPS be applied since mobile
phone alone is not within the scope of ErP requirements.  Thus is only EPS
subject to the ErP requirements?

Thanks and regards,

Scott

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[PSES] EMC/E-Mark conformity tests

[Scott Xe]

I have an in-car cell phone charger.  According to the supplier, if it is
selling alone without mentioning for cell phone charging, it does not
require E-mark compliance.  If the product mentions cell phone charging, it
requires
e-mark testing.  How is the charger tested under EMC?  What is the standard
load for the testing?  The noise source should come from the unit plugged
in, very low noise from the charger itself.

As regards to similar case of external power supply, it may be on sale
alone or come with class III products.  For selling standalone, is it
tested with e-load equivalent to the max current consumption for EMC test?

For complete set (product + EPS), must the EMC test be applied to the unit
together with EPS?

Your guidance is appreciated!

Scott

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[PSES] Class I vs Class II safety constructions

[Scott Xe]

In terms of safety level, both constructions are given the equivalent
protection against electric shock.  In electrical appliances, Class I is
used most whereas Class II is employed in most electronic products.  Is
there any background for such design route?

In some cases such as induction cookers, the enclosure is plastic/glass -
no any internal metal part exposes to the outside surfaces.  The product is
not marked with a double square symbol and comes with a 3-pin plug.  Why is
this type of product not classified as Class II rather than Class I with
the plastic/glass enclosure?

Thanks and regards,

Scott

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Re: [PSES] Transition period of new or revised standards

[Scott Xe]

John,

After Brexit, is there a body like European Forward or OJEU to set up the
in-force date and deadline to replace the current standard for a new or
revised standard?  It is a similar situation of UK standard before joining
EU?

Regards,

Scott


On Wed, 11 Sep 2019 at 17:17, John Woodgate  wrote:

> Since BSI will still be a member of CENELEC and CEN (and ETSI), the
> European Foreword will still be included. It's a 'standards body' element,
> not something inserted by the European Commission.
>
> Best wishes
> John Woodgate OOO-Own Opinions Only
> J M Woodgate and Associates www.woodjohn.uk
> Rayleigh, Essex UK
>
> On 2019-09-11 10:07, Scott Xe wrote:
>
> John,
>
> Thanks for your advice!  When will we use the National Forward?  After
> Brexit, the European Forward may not exist in BS standard, will the
> National Forward take place instead?
>
> Best regards,
>
> Scott
>
>
> On Wed, 11 Sep 2019 at 00:41, John Woodgate  wrote:
>
>> It is not a correct interpretation of 'no transition period'. The
>> European Foreword is correct, except that in rare cases, the European
>> Commission sets a different date from that set by CENELEC, in which case
>> the Commission's date applies.
>>
>> Your last sentence is correct. Docopocoss rules!
>>
>> Best wishes
>> John Woodgate OOO-Own Opinions Only
>> J M Woodgate and Associates www.woodjohn.uk
>> Rayleigh, Essex UK
>>
>> On 2019-09-10 17:15, Scott Xe wrote:
>>
>> I have a query about the transition period in BS EN standard and seeking
>> advice how to correctly interpret the transition period based on the EU
>> normal application.
>>
>>
>> For example of BS EN 60086-4 2019
>>
>>
>>
>> In European Forward of the standard, the dop is 2020-02-28 and dow
>> 2022-05-30.  Transition period is 32 months for adopting both old and new
>> standards in parallel.  The revised standard must be published no later
>> than 2020-02-28 and the deadline to replace the old standard with the new
>> one is 2022-05-30.
>>
>>
>>
>> In National Forward of BS EN IEC standard, BS EN IEC 60086-4 2019
>> supersedes BS EN 60086-04 2015, which is withdrawn.  In the UK, the old
>> standard is replaced with the new standard as soon as it is published.  Is
>> it a correct interpretation of no transition period?  It seems to be not in
>> line with above European level and below harmonized standards which both
>> have transition periods.  In addition, the implementation dates may vary by
>> each member state of EU causing unnecessary confusion.
>>
>>
>>
>> For harmonized standards, we have to follow the first publication OJ and
>> Date of cessation of presumption of conformity of superseded standard in
>> OJEU regardless of above application dates in standard.
>>
>>
>> Thanks and regards,
>>
>>
>> Scott
>>
>>
>>
>>
>>
>>> -
>> 
>>
>> This message is from the IEEE Product Safety Engineering Society emc-pstc
>> discussion list. To post a message to the list, send your e-mail to <
>> emc-p...@ieee.org>
>>
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>> http://www.ieee-pses.org/emc-pstc.html
>>
>> Attachments are not permitted but the IEEE PSES Online Communities site
>> at http://product-compliance.oc.ieee.org/ can be used for graphics (in
>> well-used formats), large files, etc.
>>
>> Website: http://www.ieee-pses.org/
>> Instructions: http://www.ieee-pses.org/list.html (including how to
>> unsubscribe) <http://www.ieee-pses.org/list.html>
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>>
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>>
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> 
>
> This message is from the IEEE Product Safety Engineering Society emc-pstc
> discussion list. To post a message to the list, send your e-mail to <
> emc-p...@ieee.org>
>
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>
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> well-used formats), large files, etc.
>
> Website: http://www.ieee-pses.org/
> Instructions: http://www.ieee-pses.org/list.html (including ho

Re: [PSES] Transition period of new or revised standards

[Scott Xe]

John,

Thanks for your advice!  When will we use the National Forward?  After
Brexit, the European Forward may not exist in BS standard, will the
National Forward take place instead?

Best regards,

Scott


On Wed, 11 Sep 2019 at 00:41, John Woodgate  wrote:

> It is not a correct interpretation of 'no transition period'. The European
> Foreword is correct, except that in rare cases, the European Commission
> sets a different date from that set by CENELEC, in which case the
> Commission's date applies.
>
> Your last sentence is correct. Docopocoss rules!
>
> Best wishes
> John Woodgate OOO-Own Opinions Only
> J M Woodgate and Associates www.woodjohn.uk
> Rayleigh, Essex UK
>
> On 2019-09-10 17:15, Scott Xe wrote:
>
> I have a query about the transition period in BS EN standard and seeking
> advice how to correctly interpret the transition period based on the EU
> normal application.
>
>
> For example of BS EN 60086-4 2019
>
>
>
> In European Forward of the standard, the dop is 2020-02-28 and dow
> 2022-05-30.  Transition period is 32 months for adopting both old and new
> standards in parallel.  The revised standard must be published no later
> than 2020-02-28 and the deadline to replace the old standard with the new
> one is 2022-05-30.
>
>
>
> In National Forward of BS EN IEC standard, BS EN IEC 60086-4 2019
> supersedes BS EN 60086-04 2015, which is withdrawn.  In the UK, the old
> standard is replaced with the new standard as soon as it is published.  Is
> it a correct interpretation of no transition period?  It seems to be not in
> line with above European level and below harmonized standards which both
> have transition periods.  In addition, the implementation dates may vary by
> each member state of EU causing unnecessary confusion.
>
>
>
> For harmonized standards, we have to follow the first publication OJ and
> Date of cessation of presumption of conformity of superseded standard in
> OJEU regardless of above application dates in standard.
>
>
> Thanks and regards,
>
>
> Scott
>
>
>
>
>
>> -
> 
>
> This message is from the IEEE Product Safety Engineering Society emc-pstc
> discussion list. To post a message to the list, send your e-mail to <
> emc-p...@ieee.org>
>
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> http://www.ieee-pses.org/emc-pstc.html
>
> Attachments are not permitted but the IEEE PSES Online Communities site at
> http://product-compliance.oc.ieee.org/ can be used for graphics (in
> well-used formats), large files, etc.
>
> Website: http://www.ieee-pses.org/
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>
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> David Heald 
>
>

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[PSES] Transition period of new or revised standards

[Scott Xe]

I have a query about the transition period in BS EN standard and seeking
advice how to correctly interpret the transition period based on the EU
normal application.


For example of BS EN 60086-4 2019



In European Forward of the standard, the dop is 2020-02-28 and dow
2022-05-30.  Transition period is 32 months for adopting both old and new
standards in parallel.  The revised standard must be published no later
than 2020-02-28 and the deadline to replace the old standard with the new
one is 2022-05-30.



In National Forward of BS EN IEC standard, BS EN IEC 60086-4 2019
supersedes BS EN 60086-04 2015, which is withdrawn.  In the UK, the old
standard is replaced with the new standard as soon as it is published.  Is
it a correct interpretation of no transition period?  It seems to be not in
line with above European level and below harmonized standards which both
have transition periods.  In addition, the implementation dates may vary by
each member state of EU causing unnecessary confusion.



For harmonized standards, we have to follow the first publication OJ and
Date of cessation of presumption of conformity of superseded standard in
OJEU regardless of above application dates in standard.


Thanks and regards,


Scott





>

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[PSES] EU Eco-design regulation & energy labelling for computer monitors

[Scott Xe]

I just received final drafts of revised Eco-design regulation 624/2009 and 
1062/2010 dated 11/03/2019 for TVs which is under the final 2-month 
consultation before published to OJ.  Surprisingly, the computer monitors are 
included in the scope of these TV regulations.  I read the 624/2009 regulation 
again and discovered that computer monitors are not included in these TV 
regulations.  That is to say computer monitors are not controlled in energy 
saving regulations until the new regulations become in force.  It is new to me 
and notice energy star logo is commonly on computer monitors.  How come doesn’t 
EU control this type of products in this area (the usage period is similar to 
TVs)?  Can someone confirm if it is the case.

 

Thanks and regards,

 

Scott


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Re: [PSES] RoHS 3 question

[Scott Xe]

Actually there are more than a dozen of amendments in 2018 and 2019
amending the exemptions of 2011/65/EU .  We have to take note of them
unless the product has a clean compliance.

Regds,

Scott


On Fri, 10 May 2019, 3:49 am John Woodgate,  wrote:

> You normally only cite the latest version. As far as I know, all these
> references end in /EU now.
>
> Best wishes
> John Woodgate OOO-Own Opinions Only
> J M Woodgate and Associates www.woodjohn.uk
> Rayleigh, Essex UK
> The UK is a sovereign state, not a Zollverein state
>
> On 2019-05-09 19:12, 06cee064502d-dmarc-requ...@ieee.org wrote:
>
> Hello group,
>
> Our products complies with all versions of RoHS including the latest one.
> When it comes to creating Declarations of conformity, do I write
> (RoHS) 2011/65/EU + 2015/863 or do I just write 2015/863? Is there an EU
> at the end of the 863?
>
> Thanks
> Peter
> -
> 
>
> This message is from the IEEE Product Safety Engineering Society emc-pstc
> discussion list. To post a message to the list, send your e-mail to <
> emc-p...@ieee.org>
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> emc-p...@ieee.org
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Re: [PSES] Product Declaration of Conformity with external PSU...

[Scott Xe]

Hi Matthew,

 

See below inline comments.

 

From: Matthew Wilson | GBE  
Sent: Wednesday, 10 April 2019 11:51 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Product Declaration of Conformity with external PSU...

 

A consumer product is powered by AA cells but also can derive its power from a 
'wall wart' mains-DC PSU via a DC jack input on the product. The client who is 
the manufacturer of the product (as per the EU directive) has decided to supply 
a third-party wall-wart PSU in the box with the product. The PSU does not carry 
the product manufacturer's logo but that of the PSU manufacturer (or possibly 
its importer/distributor assuming the responsibility of manufacturer because it 
will inevitably be made in Far East).

Scott: If the EPS is supplied together with the main unit, LVD is applicable.  
On main unit, add a marking “ Use only power supply x” as a best 
practice.



Should the product's EU Declaration of Conformity list the LVD directive? If so 
is it acceptable to list 'LVD only with specific 'manufacturer ABC' 'model XYZ' 
PSU as a clause in the DoC? I've not ever seen that done but don't see why that 
couldn't be the case.



Scott: As power supply is part of unit, one DoC is sufficient to cover and you 
are the manufacturer/importer in the EU.  If outside EU, AR is required to 
include.


Should the product's EU Declaration of Conformity also list the 2009/125/EC 
Ecodesign directive in respect of the PSU implementing measures?



Scott: Yes, EPS falls into the product group of Eco-design regulation but no 
energy label required.  It is a common practice to use one DoC for all 
applicable harmonised directives/regulations.  You are accountable for the EPS 
so you have to ensure it is safe unless the EPS is sold separately.


Maybe there should be two Declarations of Conformity in the box? One for the 
product and one for the PSU, where the latter is a copy of the PSU 
manufacturer's DoC?

Any thoughts welcome thanks.

Regards all.











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Attachments are not permitted but the IEEE PSES Online Communities site at 
http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used 
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Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe) 
 
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discussion list. To post a message to the list, send your e-mail to 


All emc-pstc postings are archived and searchable on the web at:
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Attachments are not permitted but the IEEE PSES Online Communities site at 
http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used 
formats), large files, etc.

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Instructions:  http://www.ieee-pses.org/list.html (including how to unsubscribe)
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For help, send mail to the list administrators:
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Mike Cantwell 

For policy questions, send mail to:
Jim Bacher:  
David Heald: 

Re: [PSES] Postal address on product labelling...

[Scott Xe]

Dan,

 

Thanks for your pointer!  Although the Blue Guide does not give the answer 
directly, I interpret it that EU Representative takes up the essential position 
of the manufacturer and their name and address are required as per a 
manufacturer.

 

Are the manufacturer/improper name and address required for all goods on sale 
in EU as the Blue Guide is called for EU Product Rule?

 

Thanks and regards,

 

Scott

 

From: Daniel Roman  
Sent: Monday, 25 March 2019 04:01 AM
To: Scott Xe 
Cc: EMC-PSTC@listserv.ieee.org
Subject: Re: [PSES] Postal address on product labelling...

 

You may if under RED and the manufacturer is not in the EU.  The Blue Guide is 
helpful in this regard.

 

Dan

 

 

On Thu, Mar 21, 2019 at 10:29 AM Scott Xe mailto:scott...@gmail.com> > wrote:

Only require mfr/importer name and address apart from trade mark.  Do we need 
EU AR too?

 

Rgds,

 

Scott

 

From: Dan Roman <0d75e04ed751-dmarc-requ...@listserv.ieee.org 
<mailto:0d75e04ed751-dmarc-requ...@listserv.ieee.org> > 
Sent: Thursday, 21 March 2019 10:28 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 
Subject: Re: [PSES] Postal address on product labelling...

 

Feel the pain like everyone else.  Gets to be even more fun when you are under 
RED and the manufacturer, importer, and authorized rep are all needed on the 
label because the tax laws in Europe do not line up with the Directives and 
Legal picks different company entities for each.  Now throw in Brexit and I’ll 
probably have a fourth address!  Legitimately running out of room!!!

 

Dan

 

From: Brian Kunde [mailto:bkundew...@gmail.com] 
Sent: Wednesday, March 20, 2019 10:19 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 
Subject: Re: [PSES] Postal address on product labelling...

 

The companies I have worked for over the last 40 years have relied heavily on 
international sales, so having your company's name and address on the product 
is just part of doing business.  I'm not sure what the argument is with having 
your address on the product.  My questions to those who complain would be, "Why 
Not?".  

 

As far as the requirements of EU Directives go, keep in mind that what they are 
asking for is the name and address of the responsible party for the compliance 
of the instrument. The Directive refers to this legal person or entity as the 
"Manufacturer", but that does not mean it is the company who actually builds 
the product, thou in most cases they are one and the same.   

 

Personally, I'm surprised that the writers of the EU Directives, the 
Commission, Legal Authorities in all Countries, etc.  don't require some type 
of information on ALL PRODUCT, be it an address, phone number, fax number, 
email address, website, etc. that provides IMMEDIATE RESPONSE from the 
responsible party or at least within 48 hours.  AND the system, whatever it is, 
must always be active, and only used by authorities and/or anyone regarding a 
Compliance Issue or Question.  Kind of like a reverse 911 (emergency number in 
the States).  

 

For those of you who deal in Product Safety and RoHS where you need to contact 
component manufacturers for supporting documentation knows what I'm talking 
about.  I hate it when you go to a company's website, fill out a three-page 
on-form requesting compliance information, and then never EVER getting a reply. 
 OR, you call the "corporate office" for the address that is labeled on the 
Nameplate of the product and IF you can get through to a Real Live Person, you 
asked for the Compliance Department and the person has no idea who to transfer 
you to.  After being transferred to 5 potential people you finally get ahold of 
something who says their products are built in another country somewhere and 
they "THINK" compliance is handled by them.   Does this sound at all familiar 
to anyone?  

 

Once again, I'm glad I'm over the hill and gaining speed for a head-first 
collision into the wall call retirement.  Let you young pups figure out how to 
resolve all the problems of the world.  

 

The Other Brian

 

 

 

On Wed, Mar 20, 2019 at 9:41 AM Charlie Blackham  
wrote:

Matthew

 

“But Sir, they’re not doing it” isn’t a defence in court or when you’re 
equipment is stuck in customs, or a competitor has pointed market enforcement 
authorities in your direction

 

The key phrase is “…or, where that is not possible, on its packaging or in a 
document accompanying the apparatus…..”

 

To my knowledge there’s no guidance anywhere as to “what is possible”, so it’s 
probably up to you and your lawyers 

 

Regards

Charlie

 

Charlie Blackham

Sulis Consultants Ltd

Tel: +44 (0)7946 624317  

Web:  
<https://outlook.hslive.net/owa/redir.aspx?C=02be3bf3e3a544d1bdf7b6c99fbd12f5=http%3a%2f%2fwww.sulisconsultants.com%2f>
 www.sulisconsultants.com

Registered in England and Wales, number 05466247

Re: [PSES] Postal address on product labelling...

[Scott Xe]

Brain,

 

Can I seek your guidance about mfr/importer that are required to be marked on 
products according to directives.  What is the rationale to have only these two 
operators on product?  Others are optional.  I notice that some big brands have 
only EU AR on the product.

 

Tks & rgds,

 

Scott

 

From: Brian Kunde  
Sent: Wednesday, 20 March 2019 10:19 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Postal address on product labelling...

 

The companies I have worked for over the last 40 years have relied heavily on 
international sales, so having your company's name and address on the product 
is just part of doing business.  I'm not sure what the argument is with having 
your address on the product.  My questions to those who complain would be, "Why 
Not?".  

 

As far as the requirements of EU Directives go, keep in mind that what they are 
asking for is the name and address of the responsible party for the compliance 
of the instrument. The Directive refers to this legal person or entity as the 
"Manufacturer", but that does not mean it is the company who actually builds 
the product, thou in most cases they are one and the same.   

 

Personally, I'm surprised that the writers of the EU Directives, the 
Commission, Legal Authorities in all Countries, etc.  don't require some type 
of information on ALL PRODUCT, be it an address, phone number, fax number, 
email address, website, etc. that provides IMMEDIATE RESPONSE from the 
responsible party or at least within 48 hours.  AND the system, whatever it is, 
must always be active, and only used by authorities and/or anyone regarding a 
Compliance Issue or Question.  Kind of like a reverse 911 (emergency number in 
the States).  

 

For those of you who deal in Product Safety and RoHS where you need to contact 
component manufacturers for supporting documentation knows what I'm talking 
about.  I hate it when you go to a company's website, fill out a three-page 
on-form requesting compliance information, and then never EVER getting a reply. 
 OR, you call the "corporate office" for the address that is labeled on the 
Nameplate of the product and IF you can get through to a Real Live Person, you 
asked for the Compliance Department and the person has no idea who to transfer 
you to.  After being transferred to 5 potential people you finally get ahold of 
something who says their products are built in another country somewhere and 
they "THINK" compliance is handled by them.   Does this sound at all familiar 
to anyone?  

 

Once again, I'm glad I'm over the hill and gaining speed for a head-first 
collision into the wall call retirement.  Let you young pups figure out how to 
resolve all the problems of the world.  

 

The Other Brian

 

 

 

On Wed, Mar 20, 2019 at 9:41 AM Charlie Blackham mailto:char...@sulisconsultants.com> > wrote:

Matthew

 

“But Sir, they’re not doing it” isn’t a defence in court or when you’re 
equipment is stuck in customs, or a competitor has pointed market enforcement 
authorities in your direction

 

The key phrase is “…or, where that is not possible, on its packaging or in a 
document accompanying the apparatus…..”

 

To my knowledge there’s no guidance anywhere as to “what is possible”, so it’s 
probably up to you and your lawyers 

 

Regards

Charlie

 

Charlie Blackham

Sulis Consultants Ltd

Tel: +44 (0)7946 624317

Web:  

 www.sulisconsultants.com

Registered in England and Wales, number 05466247

 

From: Matthew Wilson mailto:matthew.wil...@gbelectronics.com> > 
Sent: 20 March 2019 13:06
To: EMC-PSTC@LISTSERV.IEEE.ORG  
Subject: [PSES] Postal address on product labelling...

 

Does anyone else have endless arguments about the need to put a postal address 
on products as per the EMC and LVD requirements?  The EMC directive obliges the 
following (article 7.6 of 2014/30/EU).  The LVD also had the exact same 
obligation (article 6.6 of 2014/35/EU);

?Manufacturers shall indicate, on the apparatus, their name, registered trade 
name or registered trade mark and the postal address at which they can be 
contacted or, where that is not possible, on its packaging or in a document 
accompanying the apparatus. The address shall indicate a single point at which 
the manufacturer can be contacted. The contact details shall be in a language 
easily understood by end-users and market surveillance authorities.?

Manufacturer is, of course, meaning the entity responsible for the product 
denoted by the brand name present on the apparatus.

And every time I encounter this advice being questioned someone always says 
'But [some large entities/corporations supplying consumer products - you can 
pick your own example] don't put their address on their products.'  Well they 
should!  Maybe those devices with screens allow you to look up the address 

Re: [PSES] Postal address on product labelling...

[Scott Xe]

Only require mfr/importer name and address apart from trade mark.  Do we need 
EU AR too?

 

Rgds,

 

Scott

 

From: Dan Roman <0d75e04ed751-dmarc-requ...@listserv.ieee.org> 
Sent: Thursday, 21 March 2019 10:28 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Postal address on product labelling...

 

Feel the pain like everyone else.  Gets to be even more fun when you are under 
RED and the manufacturer, importer, and authorized rep are all needed on the 
label because the tax laws in Europe do not line up with the Directives and 
Legal picks different company entities for each.  Now throw in Brexit and I’ll 
probably have a fourth address!  Legitimately running out of room!!!

 

Dan

 

From: Brian Kunde [mailto:bkundew...@gmail.com] 
Sent: Wednesday, March 20, 2019 10:19 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG  
Subject: Re: [PSES] Postal address on product labelling...

 

The companies I have worked for over the last 40 years have relied heavily on 
international sales, so having your company's name and address on the product 
is just part of doing business.  I'm not sure what the argument is with having 
your address on the product.  My questions to those who complain would be, "Why 
Not?".  

 

As far as the requirements of EU Directives go, keep in mind that what they are 
asking for is the name and address of the responsible party for the compliance 
of the instrument. The Directive refers to this legal person or entity as the 
"Manufacturer", but that does not mean it is the company who actually builds 
the product, thou in most cases they are one and the same.   

 

Personally, I'm surprised that the writers of the EU Directives, the 
Commission, Legal Authorities in all Countries, etc.  don't require some type 
of information on ALL PRODUCT, be it an address, phone number, fax number, 
email address, website, etc. that provides IMMEDIATE RESPONSE from the 
responsible party or at least within 48 hours.  AND the system, whatever it is, 
must always be active, and only used by authorities and/or anyone regarding a 
Compliance Issue or Question.  Kind of like a reverse 911 (emergency number in 
the States).  

 

For those of you who deal in Product Safety and RoHS where you need to contact 
component manufacturers for supporting documentation knows what I'm talking 
about.  I hate it when you go to a company's website, fill out a three-page 
on-form requesting compliance information, and then never EVER getting a reply. 
 OR, you call the "corporate office" for the address that is labeled on the 
Nameplate of the product and IF you can get through to a Real Live Person, you 
asked for the Compliance Department and the person has no idea who to transfer 
you to.  After being transferred to 5 potential people you finally get ahold of 
something who says their products are built in another country somewhere and 
they "THINK" compliance is handled by them.   Does this sound at all familiar 
to anyone?  

 

Once again, I'm glad I'm over the hill and gaining speed for a head-first 
collision into the wall call retirement.  Let you young pups figure out how to 
resolve all the problems of the world.  

 

The Other Brian

 

 

 

On Wed, Mar 20, 2019 at 9:41 AM Charlie Blackham mailto:char...@sulisconsultants.com> > wrote:

Matthew

 

“But Sir, they’re not doing it” isn’t a defence in court or when you’re 
equipment is stuck in customs, or a competitor has pointed market enforcement 
authorities in your direction

 

The key phrase is “…or, where that is not possible, on its packaging or in a 
document accompanying the apparatus…..”

 

To my knowledge there’s no guidance anywhere as to “what is possible”, so it’s 
probably up to you and your lawyers 

 

Regards

Charlie

 

Charlie Blackham

Sulis Consultants Ltd

Tel: +44 (0)7946 624317

Web:  

 www.sulisconsultants.com

Registered in England and Wales, number 05466247

 

From: Matthew Wilson mailto:matthew.wil...@gbelectronics.com> > 
Sent: 20 March 2019 13:06
To: EMC-PSTC@LISTSERV.IEEE.ORG  
Subject: [PSES] Postal address on product labelling...

 

Does anyone else have endless arguments about the need to put a postal address 
on products as per the EMC and LVD requirements?  The EMC directive obliges the 
following (article 7.6 of 2014/30/EU).  The LVD also had the exact same 
obligation (article 6.6 of 2014/35/EU);

?Manufacturers shall indicate, on the apparatus, their name, registered trade 
name or registered trade mark and the postal address at which they can be 
contacted or, where that is not possible, on its packaging or in a document 
accompanying the apparatus. The address shall indicate a single point at which 
the manufacturer can be contacted. The contact details shall be in a language 
easily understood by end-users and market 

Re: [PSES] Postal address on product labelling...

[Scott Xe]

I believe that is reason why the directives lay down clear obligations of each 
economic operator.  They are not allowed to determine by themselves.

 

Rgds,

 

Scott

 

From: Nyffenegger, Dave  
Sent: Wednesday, 20 March 2019 10:51 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Postal address on product labelling...

 

Been there, done  that, heading for the wall.

 

I have seen many products that seem to be commission/distributed by a US or 
European company but actually manufactured by a third party in China or such 
which does all the compliance certification.  They don’t want to put the actual 
manufacturer contact info on the product but often these distributors are also 
not able to provide much for product specifications and compliance information 
either.

 

-Dave

 

From: Brian Kunde [mailto:bkundew...@gmail.com] 
Sent: Wednesday, March 20, 2019 10:19 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG  
Subject: Re: [PSES] Postal address on product labelling...

 

The companies I have worked for over the last 40 years have relied heavily on 
international sales, so having your company's name and address on the product 
is just part of doing business.  I'm not sure what the argument is with having 
your address on the product.  My questions to those who complain would be, "Why 
Not?".  

 

As far as the requirements of EU Directives go, keep in mind that what they are 
asking for is the name and address of the responsible party for the compliance 
of the instrument. The Directive refers to this legal person or entity as the 
"Manufacturer", but that does not mean it is the company who actually builds 
the product, thou in most cases they are one and the same.   

 

Personally, I'm surprised that the writers of the EU Directives, the 
Commission, Legal Authorities in all Countries, etc.  don't require some type 
of information on ALL PRODUCT, be it an address, phone number, fax number, 
email address, website, etc. that provides IMMEDIATE RESPONSE from the 
responsible party or at least within 48 hours.  AND the system, whatever it is, 
must always be active, and only used by authorities and/or anyone regarding a 
Compliance Issue or Question.  Kind of like a reverse 911 (emergency number in 
the States).  

 

For those of you who deal in Product Safety and RoHS where you need to contact 
component manufacturers for supporting documentation knows what I'm talking 
about.  I hate it when you go to a company's website, fill out a three-page 
on-form requesting compliance information, and then never EVER getting a reply. 
 OR, you call the "corporate office" for the address that is labeled on the 
Nameplate of the product and IF you can get through to a Real Live Person, you 
asked for the Compliance Department and the person has no idea who to transfer 
you to.  After being transferred to 5 potential people you finally get ahold of 
something who says their products are built in another country somewhere and 
they "THINK" compliance is handled by them.   Does this sound at all familiar 
to anyone?  

 

Once again, I'm glad I'm over the hill and gaining speed for a head-first 
collision into the wall call retirement.  Let you young pups figure out how to 
resolve all the problems of the world.  

 

The Other Brian

 

 

 

On Wed, Mar 20, 2019 at 9:41 AM Charlie Blackham mailto:char...@sulisconsultants.com> > wrote:

Matthew

 

“But Sir, they’re not doing it” isn’t a defence in court or when you’re 
equipment is stuck in customs, or a competitor has pointed market enforcement 
authorities in your direction

 

The key phrase is “…or, where that is not possible, on its packaging or in a 
document accompanying the apparatus…..”

 

To my knowledge there’s no guidance anywhere as to “what is possible”, so it’s 
probably up to you and your lawyers 

 

Regards

Charlie

 

Charlie Blackham

Sulis Consultants Ltd

Tel: +44 (0)7946 624317

Web:  

 www.sulisconsultants.com

Registered in England and Wales, number 05466247

 

From: Matthew Wilson mailto:matthew.wil...@gbelectronics.com> > 
Sent: 20 March 2019 13:06
To: EMC-PSTC@LISTSERV.IEEE.ORG  
Subject: [PSES] Postal address on product labelling...

 

Does anyone else have endless arguments about the need to put a postal address 
on products as per the EMC and LVD requirements?  The EMC directive obliges the 
following (article 7.6 of 2014/30/EU).  The LVD also had the exact same 
obligation (article 6.6 of 2014/35/EU);

?Manufacturers shall indicate, on the apparatus, their name, registered trade 
name or registered trade mark and the postal address at which they can be 
contacted or, where that is not possible, on its packaging or in a document 
accompanying the apparatus. The address shall indicate a single point at which 
the manufacturer can be contacted. 

Re: [PSES] RoHS standard change...

[Scott Xe]

Great, thanks, John!

 

Scott

 

From: John Woodgate  
Sent: Monday, 4 March 2019 09:05 PM
To: Scott Xe ; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] RoHS standard change...

 

Maybe my explanation was a bit too brief. CENELEC specifies the dow, but the
Commission can assert a different date - the docoposs - which is what
matters for establishing conformity.

If a standard has not been notified in the OJ, and therefore does not
support regulation, the dow is just an instruction to national standards
committees to withdraw any conflicting national standard. Manufacturers can,
perhaps unwisely, continue to apply a standard beyond the dow date in the
superseding standard.

Best wishes
John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk <http://www.woodjohn.uk> 
Rayleigh, Essex UK

On 2019-03-04 12:51, Scott Xe wrote:

Hi John,

 

Thanks for your clarification!  A lot of people will take the dow in EN
standard as the deadline, especially the standard has not been put in OJEU
or conflicts with OJEU.  EN standard is EN Norm.  What is wrong to take this
approach?  Is there any official guidance to clarify it?

 

Regards,

 

Scott

 

From: John Woodgate  <mailto:j...@woodjohn.uk>  
Sent: Friday, 1 March 2019 12:43 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 
Subject: Re: [PSES] RoHS standard change...

 

Strictly speaking, transition periods are not specified in CENELEC
standards, Instead, the mythical animal Docopocoss is specified (Date Of
Cessation Of Presumption Of Conformity Of the Superseded Standard) is
specified. Even more strictly, CENELEC specifies that, but the Commission
can overrule it.

IEC standards sometimes include a recommended transition period in the
Foreword (which no-one ever reads), but it's purely advisory.

Best wishes
John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk <http://www.woodjohn.uk> 
Rayleigh, Essex UK

On 2019-02-28 13:35, Matthew Wilson wrote:

Thank you John, that is most helpful to know that transition periods run
from the date of publication of the new standard.  Don't know why I didn't
actually have concrete knowledge of that but it makes sense.

 

Matthew Wilson,

Technical Director,

GB Electronics (UK) Ltd.

 

From: John Woodgate  <mailto:j...@woodjohn.uk>  
Sent: 27 February 2019 17:36
To: Matthew Wilson  <mailto:matthew.wil...@gbelectronics.com>
; EMC-PSTC@LISTSERV.IEEE.ORG
<mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 
Subject: Re: [PSES] RoHS standard change...

 

The site you mention has the answer:

In setting the necessary technical documentation requirements, EN IEC 63000
is almost identical to the text of EN 50581, even if any wording specific to
the EU RoHS Directive has been removed: it aims at addressing different
substance regulations worldwide while ensuring the same approach from
manufacturers everywhere. The normative references of EN 50581:2012 were
updated in EN IEC 63000 in order to reflect the latest international
development of analytical test methods and material declaration.

EN 50581:2012 is a harmonised standard meaning that its application gives
presumption of conformity with the requirements of the RoHS Directive.
Considering that a large number of products on market are referring to it in
their Declaration of Conformity, a transition period of 5 years (60 months)
has been granted for manufacturers to adapt before EN IEC 63000:2018
supersedes EN 50581:2012. In practice this means that during this transition
period both standards will coexist, allowing the manufacturers to smoothly
migrate to EN IEC 63000:2018. 

Transition periods run from the date of publication of the new standard, so
50581 is presumably usable until 2023. But you would be well advised to look
at the new standard well before then, maybe in 2021, in case the first
edition has acquired any amendment or corrigendum.

Best wishes
John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk <http://www.woodjohn.uk> 
Rayleigh, Essex UK

On 2019-02-27 16:59, Matthew Wilson wrote:

I see that BSI now state that EN 50581:2012 is marked as Status :
Superseded, Withdrawn
https://shop.bsigroup.com/ProductDetail?pid=0030261478
and states it is replaced by: BS EN IEC 63000:2018, Technical documentation
for the assessment of electrical and electronic products with respect to the
restriction of hazardous substances

The harmonised list on the EU website still states 'EN 50581:2012 Technical
documentation for the assessment of electrical and electronic products with
respect to the restriction of hazardous substances'

https://ec.europa.eu/growth/single-market/european-standards/harmonised-stan
dards/restriction-of-hazardous-substances_en

What one should I put in a declaration of conformity to be issued this week?
The product in question has been assessed for RoHS compliance using the
principles and our copy of EN 50581:2012.

It 

Re: [PSES] RoHS standard change...

[Scott Xe]

Hi John,

 

Thanks for your clarification!  A lot of people will take the dow in EN
standard as the deadline, especially the standard has not been put in OJEU
or conflicts with OJEU.  EN standard is EN Norm.  What is wrong to take this
approach?  Is there any official guidance to clarify it?

 

Regards,

 

Scott

 

From: John Woodgate  
Sent: Friday, 1 March 2019 12:43 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] RoHS standard change...

 

Strictly speaking, transition periods are not specified in CENELEC
standards, Instead, the mythical animal Docopocoss is specified (Date Of
Cessation Of Presumption Of Conformity Of the Superseded Standard) is
specified. Even more strictly, CENELEC specifies that, but the Commission
can overrule it.

IEC standards sometimes include a recommended transition period in the
Foreword (which no-one ever reads), but it's purely advisory.

Best wishes
John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk  
Rayleigh, Essex UK

On 2019-02-28 13:35, Matthew Wilson wrote:

Thank you John, that is most helpful to know that transition periods run
from the date of publication of the new standard.  Don't know why I didn't
actually have concrete knowledge of that but it makes sense.

 

Matthew Wilson,

Technical Director,

GB Electronics (UK) Ltd.

 

From: John Woodgate    
Sent: 27 February 2019 17:36
To: Matthew Wilson  
; EMC-PSTC@LISTSERV.IEEE.ORG
 
Subject: Re: [PSES] RoHS standard change...

 

The site you mention has the answer:

In setting the necessary technical documentation requirements, EN IEC 63000
is almost identical to the text of EN 50581, even if any wording specific to
the EU RoHS Directive has been removed: it aims at addressing different
substance regulations worldwide while ensuring the same approach from
manufacturers everywhere. The normative references of EN 50581:2012 were
updated in EN IEC 63000 in order to reflect the latest international
development of analytical test methods and material declaration.

EN 50581:2012 is a harmonised standard meaning that its application gives
presumption of conformity with the requirements of the RoHS Directive.
Considering that a large number of products on market are referring to it in
their Declaration of Conformity, a transition period of 5 years (60 months)
has been granted for manufacturers to adapt before EN IEC 63000:2018
supersedes EN 50581:2012. In practice this means that during this transition
period both standards will coexist, allowing the manufacturers to smoothly
migrate to EN IEC 63000:2018. 

Transition periods run from the date of publication of the new standard, so
50581 is presumably usable until 2023. But you would be well advised to look
at the new standard well before then, maybe in 2021, in case the first
edition has acquired any amendment or corrigendum.

Best wishes
John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk  
Rayleigh, Essex UK

On 2019-02-27 16:59, Matthew Wilson wrote:

I see that BSI now state that EN 50581:2012 is marked as Status :
Superseded, Withdrawn
https://shop.bsigroup.com/ProductDetail?pid=0030261478
and states it is replaced by: BS EN IEC 63000:2018, Technical documentation
for the assessment of electrical and electronic products with respect to the
restriction of hazardous substances

The harmonised list on the EU website still states 'EN 50581:2012 Technical
documentation for the assessment of electrical and electronic products with
respect to the restriction of hazardous substances'

https://ec.europa.eu/growth/single-market/european-standards/harmonised-stan
dards/restriction-of-hazardous-substances_en

What one should I put in a declaration of conformity to be issued this week?
The product in question has been assessed for RoHS compliance using the
principles and our copy of EN 50581:2012.

It appears the two are probably identical according to the link below and
we've just missed there's going to be a change (it's hard for SME like us to
keep abreast of all the changes and that before any Brexit implications!
Anyone any hints on that?) although the article talks about 60 month
transition period but not actually what the actual timescale is!

https://www.cencenelec.eu/news/brief_news/Pages/TN-2019-009.aspx

Thanks for any pointers.

Regards,




 


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